United States District Court, D. Arizona
DOMINIC W. LANZA UNITED SLATES DISTRICT JUDGE.
plaintiffs in this putative class action bought car insurance
from State Farm Mutual Automobile Insurance Company
(“State Farm”), sustained injuries in car
accidents, and then visited the same chiropractor. This
chiropractor, however, didn't receive timely payment from
State Farm because he had been flagged by an internal State
Farm anti-fraud program that sought to identify “which
doctors cause State Farm to pay the most in
automobile-accident bodily-injury claims.” (Doc. 20
¶ 59 [amended complaint].) According to Plaintiffs, this
program is actually “an elaborate scheme to avoid
paying claims by racial and ethnic minorities and members of
immigrant communities across the United States.” (Doc.
24 at 1.) Accordingly, Plaintiffs seek to assert
anti-discrimination claims against State Farm under the
Patient Protection and Affordable Care Act, 42 U.S.C. §
18116, and under 42 U.S.C. § 1981.
all of the plaintiffs reside in Minnesota. That's also
where the car accidents occurred, where the chiropractor is
based, and where the State Farm claims specialists were
located at the time they made the challenged decisions to
delay payment. The only connections between the conduct at
issue in this case and the state of Arizona are that (1)
State Farm used an Arizona “mail drop” during the
time period in question and (2) State Farm reassigned some of
the claims to an Arizona-based claims specialist in September
2018, which is after the key events occurred.
Farm has now filed a motion seeking dismissal or,
alternatively, a transfer of venue under 28 U.S.C. §
1631. (Docs. 22, 24, 26.) As explained below, the Court will
grant the motion to dismiss because it lacks personal
jurisdiction over State Farm. The company isn't subject
to general personal jurisdiction in Arizona, even though it
maintains a large facility in Arizona and has thousands of
Arizona employees, because it can't be said to “be
home” in Arizona, and it isn't subject to specific
personal jurisdiction because Plaintiffs can't
demonstrate a sufficient nexus between any of State
Farm's conduct in Arizona and their alleged injuries.
Given these conclusions, the Court need not reach State
Farm's alternative dismissal arguments under Rule
are State Farm policyholders residing in Minnesota. (Doc. 20
¶¶ 16-19.) Each was injured in an automobile
accident that occurred in Minnesota. (Id.
¶¶ 129, 142, 155.) Each received treatment from
chiropractor Jer Lee, D.C. at the Chiro Health Clinic in
Minnesota, as well as from other Minnesota-based providers.
(Id. ¶¶ 130-31, 143-44, 157-59.) Each
alleges State Farm delayed payment using a scheme targeting
racial and ethnic minorities for sham fraud investigations.
(Id. ¶¶ 1-9, 82-99, 129-73.)
November 6, 2018, Plaintiffs filed a complaint alleging that
State Farm systematically targets healthcare providers
serving minority populations and, in turn, knowingly
discriminates against minority insureds like themselves.
(See Doc. 1.) On
18, 2018, State Farm moved to dismiss the complaint for lack
of personal jurisdiction and failure to state a claim, or
alternatively, to transfer under 28 U.S.C. § 1631. (Doc.
January 8, 2019, Plaintiffs filed an amended complaint. (Doc.
January 22, 2019, State Farm filed the motion now pending
before the Court.