Quinones v. UnitedHealth Group Incorporated
1:14-cv-00497
D. Haw.Jun 28, 2017Background
- Plaintiff Juan Rios Quinones sued UnitedHealth entities asserting, among other claims, a tort claim for bad faith (Count VI) and other contract/benefit-related claims; defendants moved for summary judgment on multiple counts.
- The Court issued an order (4/18/17) granting defendants’ summary judgment on Counts IV, VI, VII, VIII and Count X of a supplemental complaint, and denying plaintiff’s partial summary judgment as moot.
- Plaintiff moved for reconsideration challenging the Court’s legal standard for the bad faith tort and relying on a November 17, 2016 deposition of defendant’s CEO (David W. Heywood) as newly discovered evidence.
- Plaintiff argued the insurer should have approved a personal mobility device (PMD) sooner, that delays were unreasonable, and that policy/contract required expedited handling; plaintiff also cited an email from his treating physician about urgency.
- The Court found plaintiff failed to show a manifest error of law or truly newly discovered evidence that would change the result, noting the deposition and related documents were available before the summary-judgment hearing and that the deposition supported defendants’ coordination-of-benefits justification rather than undermining it.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court applied the correct legal standard for a tort claim of bad faith | Best Place standard for insurance bad faith (and its progeny) applies here to support a bad-faith tort | Hawaii law limits bad-faith torts to insurance or special fiduciary/adhesive relationships; contract remedies cover ordinary breaches | Court applied correct standard; plaintiff failed to show manifest error and bad-faith tort not sustained |
| Whether newly discovered deposition evidence (Heywood) justifies reconsideration | Heywood’s deposition shows defendants’ policy prioritized third-party recovery over member needs and supports bad-faith or urgency claims | Deposition and exhibits were available pre-hearing; evidence actually supports defendants’ coordination-of-benefits position and does not create a genuine dispute | Reconsideration denied: evidence not newly discovered and would not change outcome |
| Whether defendants unreasonably delayed benefits or violated Medicaid/regulatory timelines | Delays were unreasonable; requests were urgent and should have been expedited | Defendants acted within permitted timeframes, withdrew/considered requests appropriately, and delays were due to factors outside defendants’ control | Court held no unreasonable delay or statutory violation; summary judgment for defendants upheld |
| Procedural adequacy of presenting new evidence at summary-judgment hearing | Plaintiff contends the court should have allowed presentation of Heywood evidence at hearing | Evidence was not part of the record at hearing; local rules prohibit new arguments in reply; plaintiff failed to supplement the record timely | Court declined to consider late materials/arguments and gave no relief on that basis |
Key Cases Cited
- Best Place, Inc. v. Penn Am. Ins. Co., [citation="82 Hawai'i 120, 920 P.2d 334"] (Haw. 1996) (recognizes implied covenant of good faith and context for insurance-related bad-faith claims)
- Francis v. Lee Enter., Inc., [citation="89 Hawai'i 234, 971 P.2d 707"] (Haw. 1999) (limits bad-faith tort to insurance or special-relationship contexts)
- Sung v. Hamilton, 710 F. Supp. 2d 1036 (D. Haw. 2010) (discusses Hawaii courts’ reluctance to recognize an independent tort of bad faith outside insurance/special relationships)
- Flynn v. Marriott Ownership Resorts, Inc., 165 F. Supp. 3d 955 (D. Haw. 2016) (applies Best Place and Francis in evaluating bad-faith-related claims)