Second Circuit – Long-arm jurisdiction: Northwell Health Inc. v. Group Hospitalization and Medical Services Inc.

United States Court of Appeals for the Second Circuit

Long-arm jurisdiction — Business dealings and exploitation of markets

Northwell Health Inc. v. Group Hospitalization and Medical Services Inc.

25-192

Judges Park, Perez, and Nathan

Background: The plaintiff is a healthcare provider, and it appeals from the dismissal of its complaint alleging underpayment of insurance claims by out-of-state Blue Cross Blue Shield insurers. While they do not have direct contracts with the plaintiff or sell insurance in New York, it maintains a business relationship with a Blue Cross Blue Shield insurer based in New York.

Ruling: The Second Circuit affirmed in part and reversed in part. The court held that the defendants’ purposeful dealings with a New York company and exploitation of New York’s markets for health care and insurance satisfy the requirements of New York’s long-arm statute and the Due Process clause.

John R. Horvack Jr., and Meghan F. Buckley, of Carmody Torrance Sandak & Hennessey, for the plaintiff-appellant; Misha Tseytlin and Kevin M. LeRoy, of Troutman Pepper Locke, for the defendants-appellees.

Oral argument audio