R. v. United Healthcare Insurance Company
- Gregory Woods
- 1:23-cv-04748
- U.S. District Court · Southern District of New York
- 3
In M.R. v. United Healthcare Insurance Company, Magistrate Judge Gorenstein granted Defendants’ request to seal a medical-information exhibit.
The defendants were permitted to keep United Exhibit 3 under seal, limiting public access to the exhibit’s medical information about J.S.
What happened
M.R. v. United Healthcare Insurance Company is an Employee Retirement Income Security Act health-benefits dispute involving mental-health care received by the plaintiff’s minor child, J.S. The defendants asked the court to keep United Exhibit 3 under seal.
The exhibit is a December 18, 2020 letter to United Behavioral Health containing information about J.S.’s medical history. The defendants argued that this health information was private and protected from public disclosure, including under the Health Insurance Portability and Accountability Act.
The court granted the request and directed the defendants to file the exhibit under seal on the court’s electronic filing system. Magistrate Judge Gabriel W. Gorenstein issued the order. The order did not decide the underlying benefits dispute.
The detailed version
- R. v. United Healthcare Insurance Company · No. 1:23-cv-04748
- Gregory Woods
- Sept. 13, 2023
Background
This case concerns an Employee Retirement Income Security Act (ERISA) health-benefits dispute involving mental-health care that the plaintiff’s minor child, J.S., received at Evoke at Entrada from August 20, 2020, through November 16, 2020. The defendants identified in the filing are UnitedHealthcare Insurance Company, United Behavioral Health, Pfizer Inc., and the Pfizer Health and Welfare Benefit Plan.
The defendants requested that United Exhibit 3 be filed under seal. The exhibit is a December 18, 2020 letter written by the plaintiff to United Behavioral Health. According to the defendants, the letter contains protected health information and individually identifiable information about J.S., including references to J.S.’s medical history. The defendants stated that the complaint discussed the exhibit but did not quote from it or identify specific treatment J.S. received at Evoke.
Ruling
The court granted the request. It directed the defendants to file the referenced exhibit on the court’s electronic filing system under seal. The order addressed the sealing request and did not resolve the underlying ERISA benefits dispute or the defendants’ motion to dismiss.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.