Farmer v. United States
2017 U.S. Claims LEXIS 630
Fed. Cl.2017Background
- Plaintiffs (liquidator and special deputy liquidator of Consumers’ Choice Health Ins. Co.) sued the United States seeking about $92 million in Risk Corridor Payments under 42 U.S.C. § 18062 and related claims.
- This case is one of 23 similar cases filed in the Court of Federal Claims raising the same ACA risk-corridor issue.
- Two closely related appeals raising the same legal issues—Land of Lincoln and Moda Health—are pending before the Federal Circuit and have been ordered to be considered together.
- Defendant moved to stay these proceedings pending resolution of the Federal Circuit appeals, arguing the decisions will be directly relevant and will conserve party and court resources.
- Plaintiffs conceded the appeals’ relevance but opposed what they characterized as an indefinite stay and argued defendant failed to show a pressing need.
- The court found the stay’s end point was sufficiently defined (decision(s) from the Federal Circuit) and that a stay would be reasonable and conserve resources; it granted the stay and directed the parties to file a joint status report within 14 days of the Federal Circuit decisions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to stay the case pending Federal Circuit decisions | Stay request is effectively indefinite and lacks a pressing need | Stay will conserve resources because Federal Circuit decisions are directly relevant | Grant: stay until Federal Circuit issues decisions; parties to report within 14 days |
| Whether the stay is sufficiently definite | Stay is immoderate/indefinite because end date is unknown | End point is the Federal Circuit decisions, so it is defined | Court: defined enough; not immoderate |
| Whether a pressing need must be shown for an indefinite stay | Pressing need required; defendant has not shown one | Advanced related appeals justify a stay without separate pressing need showing | Court: pressing-need showing unnecessary here given stay is reasonably limited and appeals are advanced |
| Whether judicial economy supports a stay | Concern about delay and prejudice from indefinite pause | Stay preserves resources and promotes efficient resolution with authoritative guidance | Court: judicial economy favors stay given closely related Federal Circuit appeals |
Key Cases Cited
- Cherokee Nation of Oklahoma v. United States, 124 F.3d 1413 (1997) (trial court has broad discretion to stay proceedings)
- Landis v. North Am. Co., 299 U.S. 248 (1936) (stay must be framed so its force is spent within reasonable limits)
- Hendler v. United States, 952 F.2d 1364 (1991) (discussing trial court’s power to stay proceedings)
- Kansas City Southern Ry. Co. v. United States, 181 U.S. 760 (1901) (stay considerations and balancing of competing interests)