United Healthcare of Texas, Inc., Optum Health Care Solutions LLC D/B/A Optum Healthcare Solutions, Inc., United Healthcare, Inc., D/B/A United Healthcare Insurance Company, United Healthcare Community Plan of Texas, L.L.C., Evercare of Texas, L.L.C., United Healthcare Benefits of Texas, Inc., United Healthcare Services, Inc., and UnitedHealth Group, Inc. v. Low-T Physicians Service, P.L.L.C., Low-T Physicians Professional Association, and Low-T Physicians Group, P.L.L.C.

Summary

The Texas Court of Appeals considers whether a check for approximately $24,000 tendered in response to a disputed health-insurance overpayment claim constituted an accord and satisfaction under Texas Business and Commerce Code section 3.311. The court focuses on the statutory due-diligence override for organizational knowledge and concludes that the evidence supported applying that override, making the statutory exceptions to accord and satisfaction unavailable. The court affirms the trial court’s declaratory judgment in favor of Low-T Physicians.

Holdings

1. The evidence was factually sufficient to support the trial court's finding that, within a reasonable time before collection of the check, United knew or would have known through due diligence that Low-T tendered the check in full satisfaction of the disputed claim.
2. Because the section 3.311(d) due-diligence override applied, the statutory exceptions in section 3.311(c) were unavailable as a matter of law.

Questions Presented

1. Whether the evidence was factually insufficient to support the trial court's finding that the Texas Uniform Commercial Code's due-diligence override applied to prevent United from relying on the statutory exceptions to accord and satisfaction.
2. Whether, under Texas Business and Commerce Code sections 1.202(f) and 3.311(d), United's representatives would have known of Low-T's full-satisfaction tender within a reasonable time before collection if United had exercised due diligence.

Disposition

affirmed