Nevada Supreme Court
United Healthcare INS. Co. v. Fremont Emergency Servs. (mandavia), Ltd. C/w 85656
June 12, 2025141 Nev. Adv. Op. No. 29
Summary
The Nevada Supreme Court held that ERISA did not preempt emergency-care providers’ claims against an out-of-network insurer, but the providers had no private claim under the Unfair Claims Practices Act and no implied-in-fact contract with the insurer. The court affirmed the unjust-enrichment compensatory award, upheld the denial of a new trial, vacated and reduced the punitive-damages award, reversed the Prompt Pay Act prejudgment-interest and attorney-fee awards, and denied extraordinary relief concerning record sealing. The court also directed judgment as a matter of law for the insurer on the breach-of-contract and Unfair Claims Practices Act claims.