Connecticut State Dental Ass'n v. Anthem Health Plans, Inc.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that allegations of violations of ERISA-imposed obligations rather than provider agreement-imposed obligations fell within the scope of ERISA
• holding that, while Anthem did not “link any particular assignment to a particular ERISA plan,” the claim forms submitted which noted assignment of rights were representative of assignments for services rendered and thus sufficient
• holding that the district court “abused its discretion because it did not even consider the Pioneer factors” when it simply “concluded that Plaintiffs’ counsel’s error was not excusable because counsel failed to comply with a series of orders”
• noting that the good cause inquiry is “whether prejudice results from the delay, not from having to continue to litigate the case”
• holding no independent legal duty where at least one claim was completely preempted and supplemental jurisdiction allowed the district court to exercise jurisdiction over any non-preempted state law claims
• emphasizing that a “provider that has received an assignment of benefits and has a state law claim independent of the claim arising under the assignment holds two separate claims”

Source: CourtListener parenthetical corpus (CC0).