Fairfield County Medical Ass'n v. United Healthcare of New England, Inc., 557 F. App'x 53

Associations allege defendants' removal of physicians from United Healthcare's Medicare Advantage network violated federal regulations and contractual obligations.
District court granted a preliminary injunction halting removals.
Defendants appealed claiming lack of federal subject matter jurisdiction and lack of associational standing.
Court reviews the injunction for abuse of discretion.
Court modifies the injunction to provide a 30-day arbitration window for challenged removals and otherwise affirms.
Outcome: preliminary injunction affirmed as modified.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Subject matter jurisdiction exists under federal law?	Fairfield contends a federal claim arises under Medicare regs.	United argues the claim is insubstantial and does not raise a federal controversy.	Yes; district court properly exercised jurisdiction.
Associational standing satisfied?	Members would have standing; interests germane; individual member participation not required.	No, prongs not met.	Yes; associations have associational standing.
Modification of injunction and arbitration relief?	Arbitration process can provide relief without broad injunctive scope.	Modification unnecessary.	Affirmed as modified to allow a 30-day arbitration challenge window.

Hunt v. Wash. State Apple Adver. Comm'n, 432 U.S. 333 (1977) (standing requires germane interests and no individual participation in some suits)
Warth v. Seldin, 422 U.S. 490 (1975) (prudential limits on associational standing; damages inquiries often require individual proof)
Southern New England Tel. Co. v. Global NAPs Inc., 624 F.3d 123 (2d Cir. 2010) (federal claim not insubstantial solely because merits may be weak)
In re Stock Exchs. Options Trading Antitrust Litig., 317 F.3d 134 (2d Cir. 2003) (jurisdiction not defeated when nonfrivolous federal claim exists)
Baker v. Carr, 369 U.S. 186 (1962) (rationale on jurisdiction and merits in federal-question cases)