AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• Plaintiffs Beecher Carlson Insurance Services, LLC, and California Medical Group Insurance Company Risk Retention Group sought a declaratory judgment to have DaVita Medical Group New Mexico, LLC recognized as a qualified health care provider from June 1, 2017, through December 23, 2017, despite a late-tendered surcharge. This request was made after the Office of the Superintendent of Insurance (OSI) refused to accept the late surcharge and retroactively recognize DaVita as a qualified provider for the specified period (para 1).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiffs: Argued for a de novo interpretation of the Medical Malpractice Act to require OSI to accept a late-tendered surcharge and recognize DaVita as a qualified health care provider for the period in question (para 1).
• Defendant: Contended that Plaintiffs lack standing to sue for declaratory judgment and maintained that the district court's dismissal of the declaratory judgment claim was appropriate (para 2).

Legal Issues

• Whether the district court erred in dismissing Plaintiffs’ declaratory judgment claim seeking to have DaVita recognized as a qualified health care provider despite a late-tendered surcharge (para 4).

Disposition

• The district court’s dismissal of Plaintiffs’ declaratory judgment claim was affirmed (para 10).

Reasons

• The Court, consisting of Judges Henderson, Medina, and Yohalem, unanimously agreed that the district court did not err in dismissing the declaratory judgment claim. The Court noted that Plaintiffs sought to circumvent the typical administrative process and obtain a de novo review of the Medical Malpractice Act, a tactic disfavored by New Mexico courts. The Court found that the issue was not purely legal as it involved factual disputes and required deference to OSI's expertise in interpreting the Act. The Court also highlighted that Plaintiffs' approach attempted to bypass established procedures for administrative appeals, which was not permissible. Furthermore, the Court rejected Plaintiffs' argument that procedural due process entitled them to a de novo review of the statute without deference to the agency, stating that Plaintiffs had not demonstrated that their case warranted greater procedural due process than typically provided under administrative appeal processes (paras 3-9).