This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A group of relators, employees of the New Mexico Office of the Superintendent of Insurance (OSI), alleged that Presbyterian Health Plan (PHP) and Presbyterian Insurance Company (PIC) underpaid premium taxes by improperly applying deductions and credits over a 14-year period. The relators filed a qui tam lawsuit under the Fraud Against Taxpayers Act (FATA), claiming PHP's actions resulted in significant financial losses for the state (paras 2, 4, and 11).
Procedural History
- District Court: Denied relators' claim for a share of the proceeds from an administrative recovery, finding insufficient overlap between the relators' complaint and the administrative findings (para 5).
- Court of Appeals, A-1-CA-38974: Affirmed the district court's decision, agreeing that there was no overlap between the relators' complaint and the administrative recovery (para 20).
Parties' Submissions
- Plaintiffs: Argued they were entitled to a share of the $15.6 million recovery from PHP and PIC, asserting that the recovery was a result of their original qui tam complaint (paras 2 and 5).
- Defendant: Contended that the relators were not entitled to a share of the recovery because their complaint did not specifically mention the Medical Insurance Pool (MIP) credits, which were the basis of the administrative recovery (paras 4 and 18).
Legal Issues
- Whether the relators are entitled to a share of the proceeds from the state's alternate remedy under FATA.
- What standard should be applied to determine the overlap between a relator's complaint and the state's alternate remedy (para 22).
Disposition
- The Court vacated the Court of Appeals' decision and remanded the case to the district court for further proceedings consistent with the opinion (para 68).
Reasons
Per Thomson, Chief Justice (Vigil, Bacon, Zamora JJ., and Chavez Ortega J. concurring):
The Court found that the district court applied an overly strict pleading standard, which was inappropriate for determining overlap under FATA. The Court rejected the Bledsoe standard and adopted the material elements test from the first-to-file rule, which assesses whether the relator's complaint provided the government with sufficient information to investigate related frauds. The Court emphasized that the relator's rights should not be limited by the state's choice of remedy and that the relator should have the same rights to recovery regardless of the state's actions. The case was remanded to determine if the state's alternate remedy was a continuation of the relators' original action and to apply the material elements test if necessary (paras 6, 22-24, 46-47, and 56-60).