2:24-cv-05671
E.D.N.YJan 3, 2025Background
- Plaintiff, JAY KRIPALANI M.D., P.C., sued United Healthcare for alleged underpayment of insurance benefits for medical services provided to a patient, K.R., who was covered under the American Express employee welfare benefit plan (governed by ERISA).
- The Plaintiff claims it billed $1,536,884 for services but was only paid $15,910.70 and seeks the shortfall.
- Plaintiff's complaint asserts (1) ERISA violation and (2) unjust enrichment.
- Defendant moved to dismiss on various grounds, primarily for lack of standing and ERISA preemption.
- Defendant also moved to stay discovery pending resolution of the motion to dismiss.
- Plaintiff consented to the stay of discovery, but not to the dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing under ERISA | Assignment from patient grants standing | Plaintiff is neither participant nor beneficiary; no assignment alleged in complaint | Strong showing for lack of standing, stay justified |
| ERISA preemption of state law claims | Unjust enrichment claim valid | ERISA preempts state law claims | Discovery scope may be limited if preemption applies |
| Scope and burden of discovery | N/A (consented) | Discovery may be limited to admin record | Stay granted; scope depends on dismissal motion outcome |
| Prejudice from stay | Consented; no prejudice claimed | No prejudice; focused discovery likely | No unfair prejudice, so stay appropriate |
Key Cases Cited
- Landis v. N. Am. Co., 299 U.S. 248 (power to stay proceedings inherent to court's docket management)