Worldwide Aircraft Services, Inc. v. Worldwide Insurance Services, LLC
8:24-cv-02056
M.D. Fla.Nov 18, 2024Background
- Jet ICU is an air ambulance provider that transported a patient from Jamaica to Florida, whose transport was covered by a health insurance policy issued by GeoBlue or Blue Cross Blue Shield of Alabama.
- After providing emergency services, Jet ICU sought full reimbursement for both air and ground transportation costs from the insurers.
- GeoBlue paid for air transport but only partially reimbursed the ground transport, leaving a disputed balance of $17,668.00.
- Jet ICU filed a state court lawsuit for civil theft, quantum meruit, and civil conspiracy under Florida law, all relating to the unpaid ground transport balance.
- The defendants removed the case to federal court, arguing ERISA preemption, thereby asserting federal question jurisdiction.
- The court, acting on its own initiative, examined whether it had subject matter jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ERISA preempts state law claims | Jet ICU argues it seeks state remedies for underpayment, not denial of coverage. | Defendants assert that the claims are completely preempted by ERISA. | ERISA does not completely preempt rate of payment claims in this context. |
| Federal question jurisdiction validity | Claims based on state law, no essential federal issue. | Removal proper due to ERISA preemption, creating federal jurisdiction. | No subject matter jurisdiction; remand required. |
| Sufficiency of rate-of-payment as ERISA claim | The dispute concerns rate, not right, to payment. | Characterized as a benefits claim under ERISA. | Rate of payment disputes fall outside ERISA preemption. |
| Remand appropriateness | Remand appropriate if no subject matter jurisdiction. | Case belongs in federal court due to alleged ERISA issues. | Remand granted due to lack of federal subject matter jurisdiction. |
Key Cases Cited
- Shamrock Oil & Gas Corp. v. Sheets, 313 U.S. 100 (strict construction of removal statutes and resolution of doubts in favor of remand)
- Kirkland v. Midland Mortgage Co., 243 F.3d 1277 (obligation of federal courts to determine subject matter jurisdiction)
- Univ. of S. Ala. v. Am. Tobacco Co., 168 F.3d 405 (federal courts’ duty to inquire sua sponte into subject matter jurisdiction)
- Butler v. Polk, 592 F.2d 1293 (any doubt regarding removal is resolved in favor of remand)