Abira Medical Laboratories, LLC d/b/a Genesis Diagnostics v. United HealthCare Services, Inc., et al.

Summary

The United States District Court for the District of New Jersey grants United HealthCare Services, Inc.’s motion to dismiss Abira Medical Laboratories, LLC’s Second Amended Complaint. The court declines to dismiss the ERISA claim for failure to exhaust administrative remedies at the pleading stage, but dismisses the ERISA, breach of contract, implied covenant, and quantum meruit/unjust enrichment claims for failure to identify applicable plan or contract terms and adequately plead entitlement to payment. The dismissal is without prejudice, and the plaintiff is given a final opportunity to amend.

Holdings

1. Dismissal was not warranted on exhaustion grounds because the Second Amended Complaint alleged that Plaintiff exhausted administrative remedies, and the issue could not be conclusively resolved from the pleadings at the Rule 12(b)(6) stage.
2. Plaintiff failed to state an ERISA benefits claim because it did not identify a specific ERISA plan or plan provision establishing a legally enforceable right to the benefits sought.
3. Plaintiff failed to state a breach of contract claim because it did not identify specific contractual terms, transferred through the assignments or otherwise, that obligated Defendant to pay for the laboratory services.
4. Plaintiff failed to state a claim for breach of the implied covenant because it failed to adequately plead the existence of an express or implied contract.
5. Plaintiff failed to state quantum meruit or unjust enrichment claims because it did not plausibly allege an underlying plan-based duty, a benefit consisting of discharge of that duty, or inequitable retention of such a benefit without payment.

Questions Presented

1. Whether Plaintiff's ERISA claim was subject to dismissal for failure to plead exhaustion of administrative remedies.
2. Whether Plaintiff stated an ERISA benefits claim by identifying a specific plan provision creating a legally enforceable right to benefits.
3. Whether Plaintiff adequately pleaded a breach of express or implied contract by identifying contractual terms obligating Defendant to pay for the laboratory services.
4. Whether Plaintiff adequately pleaded a breach of the implied covenant of good faith and fair dealing.
5. Whether Plaintiff adequately pleaded quantum meruit or unjust enrichment by alleging a plan-based benefit or duty retained by Defendant without payment.

Disposition

dismissed