RJ v. Cigna Behavioral Health, Inc.
- Edward Davila
- 5:20-cv-02255
- U.S. District Court · Northern District of California
- 2
In RJ v. Cigna Health and Life Insurance Co., Judge Davila denied leave to file a renewed class-certification motion because plaintiffs showed no basis to revisit the earlier denial.
RJ and DS, their proposed class, and Cigna Health and Life Insurance Company and MultiPlan, Inc.; the court’s ruling prevented plaintiffs from filing the requested renewed class-certification motion.
What happened
In RJ v. Cigna Health and Life Insurance Company, RJ and DS brought a proposed class action against Cigna Health and Life Insurance Company and MultiPlan, Inc., alleging that covered mental-health claims were not reimbursed at usual, customary, and reasonable rates under employee-benefit plans governed by the Employee Retirement Income Security Act.
The court had previously denied class certification, and the Ninth Circuit denied plaintiffs’ request for permission to appeal that decision. Plaintiffs then asked to file a renewed class-certification motion based on narrower subclasses that they would identify later.
The court denied plaintiffs’ administrative motion because they showed no change in controlling law, new material facts, clear error, or another justification for reopening class certification. Judge Davila stated that the court would set a status conference.
The detailed version
- RJ v. Cigna Behavioral Health, Inc. · No. 5:20-cv-02255
- Edward Davila
- Apr. 1, 2024
Background
RJ, acting as the representative of her beneficiary son, and DS sued Cigna Health and Life Insurance Company and MultiPlan, Inc. in a proposed class action. Plaintiffs alleged that the defendants failed to reimburse covered mental-health provider claims at usual, customary, and reasonable rates. The opinion states that the plaintiffs participated in employee-benefit plans administered by the defendants and governed by the Employee Retirement Income Security Act of 1974.
Earlier Class-Certification Ruling
On February 12, 2024, the court denied plaintiffs’ motion for class certification. The court found that plaintiffs had not shown, by the greater weight of the evidence, that their proposed class definition presented a common issue capable of being resolved for the entire class in a single decision. Plaintiffs petitioned the Ninth Circuit for permission to appeal that order, but the petition was denied on March 27, 2024.
Motion for Leave to Renew Class Certification
While the petition was pending, plaintiffs filed an administrative motion asking for permission to file a renewed motion for class certification based on narrower subclasses that they would identify later. Plaintiffs argued that the court should use its authority under Federal Rule of Civil Procedure 23, which governs class actions, and should not require them to satisfy the standard ordinarily used for reconsidering an earlier ruling. Plaintiffs also argued that they should be allowed to proceed even under that reconsideration standard.
Defendants opposed the motion. They argued that the reconsideration standard applied, that plaintiffs had not met it or shown another basis for relief, and that the scheduling order contemplated only one class-certification motion.
Ruling
The court found that a renewed motion for class certification was not warranted. It stated that plaintiffs had not shown an intervening change in controlling law, new material facts, clear error in the earlier class-certification order, or any other basis justifying a renewed motion. The court therefore denied plaintiffs’ administrative motion for leave to file a renewed motion for class certification. The court stated that it would set a status conference in the case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.