Alpha Thirteen, LLC v. Progressive Casualty Insurance Company; State Farm Mutual Automobile Insurance Company

Summary

The United States District Court for the District of Hawai‘i granted Progressive Casualty Insurance Company’s and State Farm Mutual Automobile Insurance Company’s motions to dismiss for failure to plausibly establish standing and subject-matter jurisdiction based on an allegedly unclear assignment of claims from MDX Hawaii to Alpha Thirteen, LLC. The dismissal was without prejudice and with leave to amend, limited to clarifying whether the assigned claims concern the relevant patient, with a second amended complaint due by June 16, 2026.

Holdings

1. Alpha failed to meet its burden of establishing standing because the Assignment Agreement did not clearly show that the claims listed in Schedule 1 concerned A.K. or that MDX assigned Alpha the relevant right to recover.
2. Dismissal was warranted with leave to amend because the standing deficiency had not previously been addressed by the Court and might be cured by amendment.

Questions Presented

1. Whether Alpha plausibly established Article III standing and subject matter jurisdiction by showing that MDX assigned to Alpha the right to recover on claims concerning A.K.
2. Whether dismissal for lack of subject matter jurisdiction should be with or without leave to amend.

Disposition

other