Am. Chiropractic Ass’n, Inc. v. Trigon Healthcare, Inc. (Summary)

Am. Chiropractic Ass’n, Inc. v. Trigon Healthcare, Inc., No. 1:00CV00113 (W.D. Va. July 9, 2001)

Two chiropractic associations, individual chiropractors and their patients filed suit against a health insurance company, claiming that its failure to cover chiropractic services violated federal antitrust and racketeering laws and the state insurance equality statutes. In addition, they alleged breach of contract and conspiracy to injure their trade or business. The health insurer filed a
motion to dismiss for failure to state a claim upon which relief could be granted and failure to plead fraud with particularity.

The United States District Court for the Western District of Virginia dismissed the antitrust claims of both associations for lack of standing to sue. The district court also dismissed all claims brought by the doctors on their patients’ behalf because the patients could sustain a suit on their own. In a question of first impression, the district court dismissed the racketeering charge, stating that
enforcing the racketeering claim would impede existing Virginia insurance law. The Virginia insurance equality claims were dismissed because there is no private cause of action under this statute. Judging the pleadings on their face, the district court was satisfied with the specificity of the conspiracy, monopolization, tortious interference and breach of contract theories and denied the motion
to dismiss on these counts.