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

• Three employees of the New Mexico Office of the Superintendent of Insurance (OSI) filed a qui tam action under the Fraud Against Taxpayer Act (FATA) against Presbyterian Health Plan (PHP), alleging PHP unlawfully underpaid taxes on insurance premiums from 2000 through 2014 by claiming improper credits and deductions. The Attorney General (AG) intervened, adding more defendants and reaching a settlement agreement with Presbyterian, which included immediate payment and the continuation of remaining claims through OSI administrative proceedings. The plaintiffs and the AG also agreed separately that plaintiffs would retain a right to a share of proceeds from these proceedings. However, after OSI recovered additional funds through these proceedings, it did not release any share to the plaintiffs, leading them to file a complaint for declaratory judgment seeking their share of the recovered funds (paras 2-4).

Procedural History

• District Court of Santa Fe County: Dismissed plaintiffs' complaint with prejudice, concluding they were not entitled to a share of the funds recovered by OSI from the administrative proceedings.

Parties' Submissions

• Plaintiffs: Argued they are entitled to a percentage of the funds recovered by OSI pursuant to their agreement with the AG and contended the district court misapplied FATA and ignored substantial evidence, depriving them of their rightful share of the funds.
• Defendant (OSI): Contended the AG Agreement confers upon plaintiffs whatever rights they would have in an alternate remedy proceeding under FATA, implying plaintiffs are not automatically entitled to a share of the recovered funds.

Legal Issues

• Whether the plaintiffs are entitled to a share of the funds recovered by OSI from the administrative proceedings as per their agreement with the AG.
• Whether the district court erred in its interpretation of FATA and the AG Agreement in concluding plaintiffs were not entitled to a percentage of the recovered funds.

Disposition

• The Court of Appeals affirmed the district court's judgment, concluding plaintiffs were not entitled to a share of the funds recovered by OSI from the administrative proceedings (para 27).

Reasons

• BOGARDUS, Judge (with J. MILES HANISEE, Chief Judge concurring and SHAMMARA H. HENDERSON, Judge concurring in part and dissenting in part): The court found the AG Agreement to be a valid contract but interpreted it as not entitling plaintiffs to a share of the funds recovered from the OSI administrative proceedings. It concluded that the plaintiffs' rights under the AG Agreement were limited to the proceeds from the qui tam suit settled by the Settlement Agreement. The court also found no overlap between the plaintiffs' qui tam suit and the OSI administrative proceedings regarding MIP credits, supporting the conclusion that the funds recovered did not qualify as proceeds of a claim brought by plaintiffs (paras 7-26).
  HENDERSON, Judge (concurring in part and dissenting in part): Agreed with the majority on the interpretation of the AG Agreement but dissented on the decision not to address the district court's reliance on federal FCA authority. Henderson argued for a clarification of the law regarding the pleading standard for qui tam actions and suggested remanding to the district court for further findings consistent with such clarification (paras 29-33).