Medical Association of Georgia v. Wellpoint, Inc.
756 F.3d 1222
| 11th Cir. | 2014Background
- MDL 1334 involved a nationwide physician class against WellPoint; Settlement Agreement approved Jan 3, 2006, releasing pre-Effective Date claims and enjoining Released Parties from related actions.
- UCR MDL in California charged WellPoint with underpaying for out-of-network services using the Ingenix database; ERISA and other claims were later added.
- District Court found that UCR MDL claims were Released Claims and enjoined withdrawal of those claims, leading to contempt sanctions when Appellants did not withdraw.
- Magistrate Judge Torres recommended enforcing the injunction against post-Effective Date ERISA/contract claims and RICO/antitrust claims, with some nuances for ERISA.
- Judge Moreno adopted the R&R; in 2012 the Florida court found Appellants in contempt and imposed monthly sanctions for continuing to pursue the UCR MDL claims.
- This appeal asks whether the injunction and contempt order were proper, and whether ERISA claims post-Effective Date were released or not.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the UCR MDL claims were released under §13.1(a). | Appellants argue ERISA claims post-Effective Date may not be released. | WellPoint argues the broad release barred all claims arising from MDL 1334. | Released for pre-Effective Date claims; ERISA post-Effective Date claims not released. |
| Whether RICO/antitrust claims were released. | Appellants contend post-Effective Date acts are not released. | WellPoint contends these claims arise from MDL 1334 conduct and are released. | RICO/antitrust claims barred as Released Claims. |
| Whether ERISA claims based on post-Effective Date denials/underpayments could be barred. | ERISA post-Effective Date claims could not have accrued pre-Effective Date. | Release language should bar post-Effective Date ERISA claims if they arise from the same conduct. | Post-Effective Date ERISA denials/underpayments not released; injunctive restraint vacated for those claims. |
| Whether the injunction should be vacated or narrowed on remand. | Sanctions and injunction should reflect the released/non-released split. | Injunction properly barred released claims and remained for non-released ERISA claims. | Sanctions vacated and remanded for recalibration consistent with ERISA post-Effective Date outcomes. |
| What governing standard applies to contract interpretation of settlement releases. | Court should strictly apply the release to pre-Effective Date acts only. | Court’s interpretation should be deference to its own order and Florida contract law. | De novo review of contract language; standard applied; no abuse of discretion in interpretation except for ERISA portion. |
Key Cases Cited
- In re Chira, 567 F.3d 1307 (11th Cir. 2009) (contract interpretation of settlement agreements under Florida law; de novo review)
- Thomas v. Blue Cross & Blue Shield Ass’n, 594 F.3d 814 (11th Cir. 2010) (framework for release scope: post-Effective Date acts may not be released if pre-date not addressing future claims)
- Riccard v. Prudential Ins. Co., 307 F.3d 1277 (11th Cir. 2002) (civil contempt standard requires clear and convincing evidence; deference to district court’s order)
- United States v. New York Tel. Co., 434 U.S. 159 (1977) (All Writs Act power to effectuate judgments and enjoin related litigation)
- Gulf Life Ins. Co. v. Arnold, 809 F.2d 1520 (11th Cir. 1987) (ERISA accrual principles; jurisdiction defined by denial of benefits)