PacificSource Community Health Plans v. Dean L. Cameron, in his official capacity as Director of the Idaho Department of Insurance

Summary

The United States District Court for the District of Idaho granted PacificSource Community Health Plans’s motions for a temporary restraining order and expedited consideration in its preemption challenge to Idaho enforcement proceedings. The court concluded that federal Medicare Advantage regulations likely preempted Idaho regulation of enrollment materials and broker compensation. The court enjoined the Director from enforcing Idaho unfair competition law against PacificSource based on the challenged interpretations, conditioned on a $5,000 security, and set a consolidated hearing for December 18, 2025.

Holdings

1. PacificSource established each Winter factor and was entitled to a temporary restraining order preserving the status quo while the court considered the merits and the pending motion to dismiss.
2. At the preliminary-relief stage, PacificSource was likely to succeed in showing that federal Medicare Advantage standards preempt Idaho law insofar as the state enforcement action prohibited PacificSource from removing or limiting access to enrollment materials.
3. At the preliminary-relief stage, PacificSource was likely to succeed in showing that 42 C.F.R. § 422.2274(c)(13) preempts Idaho regulation of its broker-compensation practices.
4. PacificSource’s action was properly characterized, at this stage, as a defensive declaratory judgment action that could borrow the Director’s anticipated Idaho enforcement cause of action; the court did not require PacificSource to identify an independent cause of action under the Medicare statutes.

Questions Presented

1. Whether PacificSource was entitled to a temporary restraining order under the Winter factors.
2. Whether the Medicare Advantage preemption statute and related federal regulations likely preempt Idaho’s regulation of PacificSource’s enrollment materials and broker compensation practices.
3. Whether PacificSource could pursue defensive declaratory relief by borrowing the Director’s anticipated Idaho-law enforcement cause of action.
4. Whether the temporary restraining order should be expedited, limited to the parties, and conditioned on security.

Disposition

other