Condry v. UnitedHealth Group Inc.,et.al
- Vince Chhabria
- 3:17-cv-00183
- U.S. District Court · Northern District of California
- 2
In Condry v. UnitedHealth Group, Judge Chhabria denied Teresa Harris’s motion to intervene because her proposed complaint did not allege likely future need for lactation services.
Teresa Harris’s request to join the existing lawsuit was denied. The existing plaintiffs’ class-certification efforts were not granted by this order, and United Healthcare avoided the additional litigation that intervention would have caused.
What happened
In Condry v. UnitedHealth Group, the plaintiffs sought to represent a nationwide class seeking past and future relief against United Healthcare. The court had previously identified concerns about whether any named plaintiff could seek future relief, and it denied class certification without prejudice after finding that none had the required standing.
The plaintiffs later asked to add Teresa Harris as a plaintiff. Harris alleged that United Healthcare improperly denied coverage for out-of-network lactation services and that she remained a plan participant, but she did not allege that she was likely to need lactation services again.
Judge Chhabria denied the motion to intervene. He concluded that adding Harris would unfairly prejudice United Healthcare by requiring further litigation, while Harris could bring a separate lawsuit seeking past relief and, if supported by adequate facts, future relief.
The detailed version
- Condry v. UnitedHealth Group Inc.,et.al · No. 3:17-cv-00183
- Vince Chhabria
- Dec. 19, 2019
Background
Six named plaintiffs filed the lawsuit in early 2017 against United Healthcare and sought to represent a nationwide class. They requested both retrospective relief, meaning relief for past alleged injuries, and prospective relief, meaning relief addressing future injuries.
The court had raised concerns about whether any named plaintiff had standing—the legal requirement that a plaintiff show a sufficient personal connection to the requested relief—to seek prospective relief. During the case, the plaintiffs did not add a plaintiff who was qualified to seek that relief. The court later denied the plaintiffs’ first motion for class certification, identifying several problems, including the absence of a named plaintiff with standing to seek prospective relief. The denial was without prejudice to seeking certification of a narrower class based on stronger evidence.
Motion to Intervene
After additional discovery, the plaintiffs renewed their class-certification request and moved to intervene on behalf of Teresa Harris. The proposed complaint alleged that Harris had been improperly denied coverage for out-of-network lactation services and remained a United Healthcare plan participant. It did not allege facts showing that Harris was likely to need lactation services in the future.
The court concluded that these allegations did not establish Harris’s standing to seek prospective relief. The court relied on the requirement that a plaintiff seeking an injunction must show a likelihood of future injury.
Ruling
Judge Vince Chhabria denied the motion to intervene. The court found that granting the motion would unfairly prejudice United Healthcare because the case was nearing its end and adding Harris would likely lead to another motion to dismiss for lack of standing, additional discovery if the defects could be cured, another summary-judgment motion, and another request to certify a prospective-relief class.
The court found no comparable prejudice to Harris from denial because she remained free to file a separate lawsuit against United Healthcare seeking retrospective relief and, if she could allege the necessary facts, prospective relief. The order denied the motion to intervene; it did not state that the broader case was dismissed.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.