Anthem Health Plans of Maine, Inc. v. Superintendent of Insurance, 18 A.3d 824

Anthem challenged the Superintendent of Insurance's 2009 rate decision for individual health policies, arguing a 3% built-in profit margin was required and 0% profit was improper.
The 2009 rate decision approved a 10.9% average increase with 0% profit for Anthem; Anthem sought a 18.5% increase with 3% profit instead.
During the pendency, 2010 rates were considered, resulting in an approved 0.5% profit margin for 2010.
Anthem filed a Rule 80C petition in Superior Court seeking vacatur and remand for a 3% profit; case transferred to the Business and Consumer Docket and affirmed.
The 2009 rate year had already passed, and Anthem could not recover higher rates from subscribers, raising mootness concerns.
The Supreme Judicial Court dismissed Anthem’s appeal as moot, noting potential regulatory changes at federal and state levels and the absence of effective relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the case is moot.	Anthem argues the controversy remains live for guidance on future rate setting.	The matter is moot because the 2009 rate year has passed and no live relief is available.	Yes, moot; appeal dismissed.
Whether any mootness exception applies here.	If the issues are capable of repetition and evading review, the case should proceed.	No applicable exception; regulatory changes undermine recurrence or public concern justifying review.	No exception applies.

Smith v. Hannaford Bros. Co., 2008 ME 8 (Me. 2008) (mootness exceptions and limited judicial resources)
Lewiston Daily Sun v. Sch. Admin. Dist. No. 43, 1999 ME 143 (Me. 1999) (mootness and limited resources)
Me. Sch. Admin. Dist. No. 37 v. Pineo, 2010 ME 11 (Me. 2010) (fleeting nature of administrative decisions; mootness exceptions)
Me. Civil Liberties Union v. City of So. Portland, 1999 ME 121 (Me. 1999) (prudential limits on review where issues unlikely to recur)