598 S.W.3d 237
Tex.2020Background
- Rodney Beasley was injured in a 2007 car accident and received medical bills with providers’ list rates totaling $2,662.54.
- Beasley’s health insurer (BCBS) had negotiated reimbursement rates with providers and paid $1,068.90; providers accepted that as full payment and did not seek the balance from Beasley.
- Beasley also was a covered person under a PIP policy (Farmers) with a $2,500 maximum covering “reasonable expenses incurred for necessary medical … services.”
- Beasley submitted the provider statements and Farmers paid $1,068.90; he demanded the remaining $1,431.10 (the difference to the $2,500 policy limit) and sued alleging breach of contract and statutory violations.
- The trial court dismissed for lack of standing; the court of appeals reversed, but the Texas Supreme Court reversed the court of appeals and dismissed the suit for want of jurisdiction, holding Beasley alleged no actual or threatened injury because he owed no out‑of‑pocket medical amounts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Beasley had standing to sue Farmers after Farmers paid negotiated amounts accepted by providers rather than providers’ list rates | Beasley: Farmers breached the PIP policy by paying less than the policy limit; alleging unreasonable benefit reduction is enough to establish standing to recover the policy difference | Farmers: PIP covers medical expenses actually incurred; because providers accepted BCBS’s negotiated payment as full payment, Beasley incurred only $1,068.90 and suffered no actual or threatened injury | Held: No standing. Because Beasley had no unreimbursed, out‑of‑pocket medical expenses and providers accepted negotiated payment, he alleged no concrete injury and the suit was dismissed for lack of jurisdiction |
Key Cases Cited
- Allstate Indem. Co. v. Forth, 204 S.W.3d 795 (Tex. 2006) (insured lacked standing where providers accepted insurer’s payment and insured alleged no unreimbursed expenses)
- Haygood v. De Escabedo, 356 S.W.3d 390 (Tex. 2011) (insurer’s negotiated reductions are a benefit to the insurer, not a collateral‑source benefit to the insured)
- Heckman v. Williamson Cnty., 369 S.W.3d 137 (Tex. 2012) (standing is a constitutional prerequisite; plaintiff must allege a concrete, particularized injury)