Case 3:23-cv-01135-OAW Document 1 Filed 08/25/23 Page 1 of 26

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

PAIGE VAN PELT, Individually and On Civil Action No. __________________

Behalf of All Others Similarly Situated,

Plaintiff, CLASS ACTION COMPLAINT

v.
JURY TRIAL DEMANDED
THE CIGNA GROUP, CIGNA
CORPORATION, and CIGNA HEALTH
AND LIFE INSURANCE COMPANY.

Defendants.
Dated: August 25, 2023

Plaintiff Paige Van Pelt (“Plaintiff”), individually and on behalf of all others similarly

situated, brings the following complaint against The Cigna Group, Cigna Corporation, and Cigna

Health and Life Insurance Company (collectively “Cigna” or “Defendants”), and alleges as

follows, based upon information and belief and investigation of counsel, except as to the

allegations specifically pertaining to Plaintiff, which are based on her personal knowledge.

I. INTRODUCTION

1. Every year tens of millions of Americans receive preventative and life-saving

medical treatment, only to be confronted with a bill that makes their lives exponentially more

difficult. Indeed, the United States has one of the highest healthcare costs in the world. In 2021,

U.S. healthcare reached $4.3 trillion, which averages to approximately $12,900 per person. In

stark contrast, a recent study from Fortune found that more than half of all Americans are living

paycheck to paycheck. This reality leaves Americans with an impossible choice: have food on the

table or pay their medical bills.

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2. Americans have one primary bulwark against this unfortunate reality, and that lies

with their medical insurers. The role of medical insurers is purportedly to defend their clients from

impossible financial medical burdens, through promoting proactive healthcare prevention,

providing coverage for medically necessary health care services and procedures for individuals

and families, and protecting people financially from exceptional health care costs. In this regard,

medical insurers are not only the gateway to health care services but are fiduciaries.

3. Cigna is the one of the largest medical insurers in the United States.1

4. Despite its role in protecting already over-burdened Americans from healthcare-

induced financial hardship, Cigna has leveraged its sophisticated infrastructure and automated

intelligence capabilities to systematically defraud its consumers by denying medically necessary

claims en masse without appropriate physician review, in violation of state and federal consumer

protection laws.2 Cigna’s practices thus, have caused Plaintiff and the putative Class to pay for

medical services that should have otherwise been approved under plan terms and enable Cigna to

save millions, if not billions, of dollars on its bottom line.

5. Cigna furthered this scheme to defraud Plaintiff and the Class through an automated

intelligence system referred to as “procedure-to-diagnosis” (referred to as “PxDx”). PxDx allows

Cigna medical directors to automatically deny a claim purportedly on medical grounds without

making a medically necessary determination or even opening the patient file, leaving patients with

unexpected bills that should have been covered and paid. Indeed, Cigna automatically denies

1
Out of all the companies in the United States, Cigna was ranked fifteen in the 2023 Fortune 500 list of largest
U.S. corporation by total revenue—revenue for the twelve months ending June 30, 2023 was $186.135B, a 3.72%
increase year-over-year.
2
As alleged herein, Cigna engaged in unfair claim settlement practices by inter alia, “refusing to pay claims
without conducting a reasonable investigation based upon all available information.” See Conn. Gen. Stat. §38a-
816(6)(D).

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claims because it knows that most patients will either pay such bills or forego the procedures,

rather than deal with the hassle of appealing a denial.

6. The impact on Cigna’s insureds is devastating. Indeed, as discussed further below,

in a period of just over two months, Cigna medical directors reportedly automatically denied,

without review, over 300,000 requests for payments, spending an average of 1.2 seconds on each

case.

7. Cigna’s self-interest is obvious — the more claims it automatically denies (even

without any justification), the more money it saves and the larger its profits are. This is all the

more egregious because Cigna is a fiduciary to Plaintiff and the Class. Cigna must interpret the

terms of each plan as a fiduciary, and it has breached its duty of care and loyalty to Plaintiff and

the Class by systematically denying claims without proper review. Moreover, Cigna did not

provide the coverage that it was obligated to provide under the health plan.

8. Plaintiff and the Class are therefore not receiving the benefits they have paid for,

and in many cases are left paying out-of-pocket for medical care that should have been covered by

Cigna. Plaintiff and the Class have been harmed through inter alia, violations of the Connecticut

Unfair Trade Practices Act through violating the Connecticut Unfair Insurance Practices Act and

the Connecticut Corrupt Organizations and Racketeering Activity Act, breach of contract, as well

as violations of the covenant of good faith and fair dealing, and unjust enrichment. Plaintiff seeks

all compensatory, punitive, injunctive, equitable, and all other relief as permissible by law on

behalf of herself and the putative Class.

II. JURISDICTION AND VENUE

9. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §1332(a) because

the amount in controversy exceeds $75,000.00, and Plaintiff and Cigna are residents and citizens

of different states.

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10. The Court has personal jurisdiction over Defendants because they do business in

the District of Connecticut and have sufficient minimum contacts with the District. Defendants

intentionally avail themselves of the markets in this State through the promotion, marketing, and

operations of their platforms at issue in this lawsuit in Connecticut, and by retaining the profits

and proceeds from these activities, to render the exercise of jurisdiction by this Court permissible

under Connecticut law.

11. Venue in this Court is proper under 28 U.S.C. §§1391(b)(1), (2), (3), and (c)(2).

Defendants are headquartered in this District, reside in this District, and a substantial part of the

events or omissions giving rise to the claims at issue in this Complaint arose in this District, and

Cigna is subject to the Court’s personal jurisdiction with respect to this action.

III. PARTIES

Plaintiff

12. Plaintiff resides in Aitkin, Minnesota and was enrolled in a self-funded Cigna Plan

throughout 2018. The written terms of this Plan provided benefits for covered health care services.

The Plan further specified that Cigna provides claim administration services to the Plan as the

party delegated with authority to interpret and apply the terms of financial disbursement. Plaintiff

has Lynch Syndrome — a type of inherited cancer syndrome associated with a genetic

predisposition to different cancer types. In order to prevent cancerous growths, Plaintiff is required

to have a colonoscopy once every 1-2 years. In 2018, Cigna automatically denied coverage for

her colonoscopy and endoscopy, because the clinic coded it as diagnostic instead of preventative.

As a result, Plaintiff was charged $3,200 which has since been sent to collections. Plaintiff has

been financially damaged by Cigna’s practices, and her credit score lowered as a result of being

automatically denied coverage for the preventative care that she desperately required. Had

Plaintiff known that Cigna had a practice of automatically and algorithmically denying claims and

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that the healthcare disbursements she required would be financially withheld, she would have

enrolled with another plan or paid less for her plan had their bargaining power been equal.

Defendants

13. The Cigna Group is a for-profit American multinational managed healthcare and

insurance company based in Bloomfield, Connecticut and incorporated in Delaware.

14. Cigna Corporation conducts insurance and operations for the The Cigna Group and

is headquartered at 900 Cottage Grove Road, Bloomfield, Connecticut 06002, and incorporated in

Connecticut.

15. Cigna Health and Life Insurance Company markets and issues health insurance and

is also headquartered at 900 Cottage Grove Road, Bloomfield, Connecticut 06002, and

incorporated in Connecticut.

16. The Cigna Group, Cigna Corporation, and Cigna Health and Life Insurance

Company are referred to herein as “Cigna”.

IV. FACTUAL ALLEGATIONS

17. Cigna is engaging in unfair claim settlement practices by, inter alia, “refusing to

pay claims without conducting a reasonable investigation based upon all available information.”

Conn. Gen. Stat. § 38a-816(6)(D).

18. A March 2023 article from ProPublica identified Cigna’s use of this program to

deny claims without review of medical records.3

3
See Patrick Rucker, Maya Miller, and David Armstrong, How Cigna Saves Millions by Having Its Doctors
Reject Claims Without Reading Them, PROPUBLICA, https://www.propublica.org/article/cigna-pxdx-medical-health-
insurance-rejection-claims (last updated April 14, 2023).

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19. For example, over a period of two months, Cigna doctors reportedly denied over

300,000 requests for payments using PxDx, spending an average of 1.2 seconds on each case,

documents submitted to reporters at ProPublica show.4

20. “Before health insurers reject claims for medical reasons, company doctors must

review them, according to insurance laws and regulations in many states. Medical directors are

expected to examine patient records, review coverage policies and use their expertise to decide

whether to approve or deny claims, regulators said. This process helps avoid unfair denials.”5

21. “But the Cigna review system . . . bypasses those steps. Medical directors do not

see any patient records or put their medical judgment to use, said former company employees

familiar with the system. Instead, a computer does the work. A Cigna algorithm flags mismatches

between diagnoses and what [Cigna] considers acceptable tests and procedures for those ailments.

Company doctors then sign off on the denials in batches, according to interviews with former

employees who spoke on condition of anonymity.”6

22. ProPublica article further reported that its investigation revealed that former Cigna

employees admitted that “medical directors do not see any patient records or put their medical

judgment to use.” Instead, PXDX utilizes an algorithm to determine whether to approve or deny

claims and that Cigna’s “doctors then sign off on the denials in batches.” A former employee from

Cigna stated: “‘We literally click and submit,’ one former Cigna doctor said. ‘It takes all of 10

seconds to do 50 at a time.’”7

4
Id.
5
Id.
6
Id.
7
Id.

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23. “Not all claims are processed through this review system. For those that are, it is

unclear how many are approved and how many are funneled to doctors for automatic denial.”8

24. On information and belief, Cigna’s “PxDx” review system was developed more

than a decade ago by a former pediatrician.

25. In 2010, Dr. Alan Muney (“Muney”) was “managing health insurance for

companies owned by Blackstone, the private equity firm, when Cigna tapped him to help spot

savings in its operation.”9

26. “Insurers have wide authority to reject claims for care, but processing those denials

can cost a few hundred dollars each, former executives said. Typically, claims are entered into the

insurance system, screened by a nurse and reviewed by a medical director.”10

27. “At Cigna, Muney and his team created a list of tests and procedures approved for

use with certain illnesses. The system would automatically turn down payment for a treatment that

didn’t match one of the conditions on the list. Denials were then sent to medical directors, who

would reject these claims with no review of the patient file.”11

28. “Cigna eventually designated the list “PxDx” — corporate shorthand for procedure-

to-diagnosis. The list saved money in two ways. It allowed Cigna to begin turning down claims

that it had once paid. And it made it cheaper to turn down claims, because the company’s doctors

never had to open a file or conduct any in-depth review. They simply denied the claims in bulk

with an electronic signature.”

8
Id.
9
Id.
10
Id.
11
Id.

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29. “‘The PxDx stuff is not reviewed by a doc or nurse or anything like that,’ Muney

said.”12

30. “The review system was designed to prevent claims for care that Cigna considered

unneeded or even harmful to the patient, Muney said. The policy simply allowed Cigna to cheaply

identify claims that it had a right to deny.”13

31. “[T]wo former Cigna doctors, who did not want to be identified by name for fear

of breaking confidentiality agreements with Cigna, said the system was unfair to patients. They

said the claims automatically routed for denial lacked such basic information as race and gender.”14

32. “‘It was very frustrating,’ one doctor said.”15

33. “Medicare and Medicaid have a system that automatically prevents improper

payment of claims that are wrongly coded. It does not reject payment on medical grounds.”16

34. “Within the world of private insurance, Muney is certain that the PxDx formula has

boosted the corporate bottom line. ‘It has undoubtedly saved billions of dollars,’ he said.”17

35. “Insurers benefit from the savings, but everyone stands to gain when health care

costs are lowered and unneeded care is denied, he said.”18

12
Id.
13
Id.
14
Id.
15
Id.
16
Id.
17
Id.
18
Id.

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36. “Cigna carefully tracks how many patient claims its medical directors handle each

month. Twelve times a year, medical directors receive a scorecard in the form of a spreadsheet that

shows just how fast they have cleared PxDx cases.”19

37. One doctor “rejected 121,000 claims in the first two months of 2022, according to

the scorecard[,]”:20

38. “Dr. Richard Capek, another Cigna medical director, handled more than 80,000

instant denials in the same time span, the spreadsheet showed.”21

39. “Dr. Paul Rossi has been a medical director at Cigna for over 30 years. Early last

year, the physician denied more than 63,000 PxDx claims in two months.”22

40. “Cigna knows that many patients will pay such bills rather than deal with the hassle

of appealing a rejection, according to . . . former employees of the company. The PxDx list is

19
Id.
20
Id. (quote and scorecard image).
21
Id.
22
Id.

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focused on tests and treatments that typically cost a few hundred dollars each, said former Cigna

employees.”23

41. “Muney and other former Cigna executives emphasized that the PxDx system does

leave room for the patient and their doctor to appeal a medical director’s decision to deny a

claim.”24

42. “But Cigna does not expect many appeals. In one corporate document, Cigna

estimated that only 5% of people would appeal a denial resulting from a PxDx review.”25

43. “In 2014, Cigna considered adding a new procedure to the PxDx list to be flagged

for automatic denials.”26

44. “Autonomic nervous system testing can help tell if an ailing patient is suffering

from nerve damage caused by diabetes or a variety of autoimmune diseases. It’s not a very

involved procedure – taking about an hour – and it costs a few hundred dollars per test.”27

45. “The test is versatile and noninvasive, requiring no needles. The patient goes

through a handful of checks of heart rate, sweat response, equilibrium and other basic body

functions.”28

46. “At the time, Cigna was paying for every claim for the nerve test without bothering

to look at the patient file, according to a corporate presentation. Cigna officials were weighing the

23
Id.
24
Id.
25
Id.
26
Id.
27
Id.
28
Id.

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cost and benefits of adding the procedure to the list. ‘What is happening now?’ the presentation

asked. ‘Pay for all conditions without review.’”29

47. “By adding the nerve test to the PxDx list, Cigna officials estimated, the insurer

would turn down more than 17,800 claims a year that it had once covered. It would pay for the test

for certain conditions, but deny payment for others.”30

48. “These denials would ‘create a negative customer experience’ and a ‘potential for

increased out of pocket costs,’ the company presentation acknowledged.”31

49. “But they would save roughly $2.4 million a year in medical costs, the presentation

said.”32

50. As one doctor said, “It’s not good medicine. It’s not caring for patients. You end

up asking yourself: Why would they do this if their ultimate goal is to care for the patient?”33

V. CLASS ALLEGATIONS

51. Plaintiff brings this class action lawsuit pursuant to Federal Rules of Civil

Procedure 23(a) and (b)(3) and/or (b)(2) and/or (c)(4) on behalf of a Nationwide Class and

Minnesota Subclass as defined as follows:

NATIONWIDE CLASS

52. Under Fed. R. Civ. P. 23(b)(2) and (b)(3), as applicable, and (c)(4), Plaintiff seeks

certification of a Nationwide Class defined as follows:

29
Id.
30
Id.
31
Id.
32
Id.
33
Id.

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All persons in the United States and its territories who had their
claims approved or denied using the PxDx automated review
process.

STATE SUBCLASS

53. In addition to, or as an alternative to, the Nationwide Class and according to Rule

23(c)(5), Plaintiff seeks to represent all members of the following Subclass of the Nationwide

Class (“Minnesota Subclass”) for the jurisdiction below:

MINNESOTA

All persons who reside in the State of Minnesota who had their
claims approved or denied using the PxDx automated review
process.

54. Plaintiff reserves her right, before the Court determines whether certification is

appropriate, to redefine the proposed Nationwide Class, or to propose subclasses, if necessary,

including, but not limited to, state subclasses and/or entity subclasses.

55. Unless otherwise stated, the above-defined Nationwide Class and the Minnesota

Subclass are referred to as the “Class.”

56. Excluded from the Class are Defendants and their officers, executives, subsidiaries

and affiliates; governmental entities; and the Judge to whom this case is assigned and their

immediate family. Plaintiff reserves the right to revise the definition of any Class based on

information learned through discovery.

57. Certification of Plaintiff’s claims for class-wide treatment is appropriate because

Plaintiff can prove the elements of her claims on a class-wide basis using the same evidence as

would be used to prove those elements in individual actions alleging the same claims.

58. This action has been brought and may be properly maintained on behalf the Class

proposed herein under Rule 23.

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59. Numerosity: Rule 23(a)(1): The members of the Class are so numerous and

geographically dispersed that individual joinder of all Class Members is impracticable. While

Plaintiff is informed and believes (based on publicly available reports concerning the PxDx claims

process) that there are at least tens of thousands of Class Members, the precise number of Class

Members is unknown to Plaintiff. Still, it may be ascertained from Cigna’s books and records.

60. Commonality and Predominance: Rule 23(a)(2) and (b)(3): This action involves

common questions of law and fact which predominate over any questions affecting individual

Class Members, including, without limitation:

a. Whether Cigna engaged in the conduct alleged herein;

b. Whether Cigna had a duty to disclose relevant information about PxDx;

c. Whether Cigna concealed and omitted information about PxDx;

d. Whether Cigna breached contracts;

e. Whether Plaintiff and other Class Members are entitled to declaratory

judgment;

f. Whether Plaintiff and other Class Members are entitled to equitable relief,

including a preliminary injunction;

g. Whether Cigna was or is obligated to inform Class Members of any

potential claims; and

h. Whether Plaintiff and the other Class Members are entitled to damages and

other monetary relief and, if so, in what amount.

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61. Typicality: Federal Rule of Civil Procedure 23(a)(3): Plaintiff’s claims are typical

of the other Class Members’ claims because, among other things, all Class Members were

comparably injured through Cigna’s wrongful conduct as described above.

62. Adequacy: Federal Rule of Civil Procedure 23(a)(4): Plaintiff is an adequate Class

Representative because her interests do not conflict with the interests of the other Class Members

she seeks to represent; Plaintiff has retained counsel competent and experienced in complex class

action litigation and Plaintiff intends to prosecute this action vigorously. Plaintiff and her counsel

will fairly and adequately protect the Class’s interests.

63. Declaratory Relief: Federal Rule of Civil Procedure 23(b)(2): Cigna has acted or

refused to act on grounds generally applicable to Plaintiff and Class Members, thereby making

declaratory relief appropriate with respect to each Class as a whole.

64. Superiority: Federal Rule of Civil Procedure 23(b)(3): A class action is superior

to any other available means for the fair and efficient adjudication of this controversy and no

unusual difficulties are likely to be encountered in the management of this class action. The

damages or other financial detriment suffered by Plaintiff and the other Class Members are

relatively small compared to the burden and expense that would be required to individually litigate

their claims against Defendants, so it would be impracticable for the Class Members to individually

seek redress for Cigna’s wrongful conduct. Even if Class Members could afford individual

litigation, such litigation creates a potential for inconsistent or contradictory judgments. It

increases the delay and expense to all parties and the court system. By contrast, a class action is

suited and intended to manage such difficulties and provide the benefits of uniform and common

adjudication, economy of scale, and comprehensive supervision.

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VI. TOLLING OF STATUTE OF LIMITATIONS

Discovery Rule Tolling

65. Class Members had no way of knowing about Cigna’s deception concerning the

use of PxDx in the clams approval process.

66. Within the time period of any applicable statutes of limitation, Plaintiff and other

Class Members could not have discovered through the exercise of reasonable diligence that Cigna

was fraudulently, deceptively, and unfairly utilizing PxDx in the claims approval process in breach

of their contracts and to the direct benefit of Cigna.

67. For these reasons, all applicable statutes of limitation have been tolled by operation

of the discovery rule for the claims asserted herein.

Fraudulent Concealment Tolling

68. All applicable statutes of limitation have also been tolled by Cigna’s knowing and

active fraudulent concealment and denial of the facts alleged herein throughout the time period

relevant to this action.

69. Rather than disclose that an automated system denied Plaintiff’s claims, Defendants

falsely represented that the claims process had been supervised by medical personal in accordance

with state and federal regulations.

Estoppel

70. Defendants were under a continuous duty to disclose their unfair and unlawful

conduct to Plaintiff and the Class. Based on the above, Cigna is estopped from relying on any

statutes of limitations in defense of this action.

VII. CHOICE OF LAW PROVISIONS

71. Because Plaintiff brings this complaint in Connecticut, Connecticut’s choice of law

regime governs the state law allegations in this complaint. Under Connecticut’s choice of law

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rules, Connecticut law applies to the claims of all Class Members, regardless of their state of

residence, as Plaintiff believes there is no conflict between Connecticut’s law and the laws of other

states with an interest in the outcome of this litigation.

72. Cigna’s headquarters are and were in Connecticut, and the misconduct complained

of originated in Connecticut. All Class Members — even those who never stepped foot in

Connecticut but had a Cigna policy — directly implicate Connecticut’s interest in regulating

businesses and commerce.

73. Because Cigna sells policies in Connecticut and the subject matter of this litigation

arises under Cigna’s connections to Connecticut, Connecticut has a strong interest in regulating

businesses and commerce in the States.

VIII. CLAIMS FOR RELIEF

COUNT ONE

VIOLATION OF CONNECTICUT UNFAIR TRADE PRACTICES ACT (“CUTPA”)

THROUGH VIOLATION OF THE CONNECTICUT UNFAIR INSURANCE
PRACTICES ACT (“CUIPA”)
(On Behalf of the Nationwide Class and Minnesota Subclass)

74. Plaintiff repeats, reasserts, and incorporates the allegations contained in paragraphs

1 - 73 as if fully set forth herein.

75. Cigna has acted, as alleged herein, in the conduct of trade or commerce as defined

in Conn. Gen. Stat. §42-110a(4).

76. CUIPA states, “No person shall engage in this state in any trade practice which is

defined in section 38a-816 as, or determined pursuant to sections 38a-817 and 38a-818 to be, an

unfair method of competition or an unfair or deceptive act or practice in the business of insurance,

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nor shall any domestic insurance company engage outside of this state in any act or practice defined

in subsections (1) to (12), inclusive, of section 38a-816.”34

77. Cigna engaged in unfair claim settlement practices by inter alia, “refusing to pay

claims without conducting a reasonable investigation based upon all available information.” See

Conn. Gen. Stat. §38a-816(6)(D).

78. Cigna has also regularly been engaged in the following conduct in violation of

CUIPA: (i) misrepresenting “the benefits, advantages, conditions, or terms of any insurance

policy” in violation of Conn. Gen. Stat. §38a-816(1)(A); (ii) “[m]aking, publishing, disseminating,

circulating or placing before the public, or causing, directly or indirectly, to be made, published,

disseminated, circulated or placed before the public, in a newspaper, magazine or other

publication, or in the form of a notice, circular, pamphlet, letter or poster, or over any radio or

television station, or in any other way, an advertisement, announcement or statement containing

any assertion, representation or statement with respect to the business of insurance or with respect

to any person in the conduct of his insurance business, which is untrue, deceptive or misleading”

in violation of Conn. Gen. Stat. §38a-816(2); and (iii) “[m]aking false or fraudulent statements or

representations on or relative to an application for an insurance policy for the purpose of obtaining

a fee, commission, money or other benefit from any insurer, producer or individual” in violation

of Conn. Gen. Stat. §38a-816(8).

79. Cigna’s violations of CUIPA are violations of the Connecticut Unfair Trade

Practices Act (“CUTPA”), Conn. Gen. Stat. §42-110b(a) and give rise to a cause of action under

Conn. Gen. Stat. §42-110g(a).

34
Conn. Gen. Stat. §38a-815

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80. Cigna’s conduct is part of a general business practice that constitutes unfair and

deceptive acts in violation of Conn. Gen. Stat. §42-110b(a).

81. As a direct and proximate result of Cigna’s violation of CUTPA, Conn. Gen. Stat.

§42-110b(a), Plaintiff and the Class members have suffered ascertainable losses under Conn. Gen.

Stat. §42-110g(a) in an amount to be proved at trial.

82. As a result of Cigna’s unfair and/or deceptive acts or practices, Cigna has reaped

ill-gotten profits and gains, which they otherwise would not have received and which in equity,

they should be required to disgorge.

83. Cigna is liable, pursuant to Conn. Gen. Stat. §42-110g(a), for punitive damages.

84. Furthermore, Cigna is liable, pursuant to Conn. Gen. Stat. §42-110g(d), for costs

and reasonable attorneys’ fees.

85. Plaintiff also seeks an injunction on behalf of himself and the Class prohibiting

Cigna from violating CUTPA and/or CUIPA, and breaching the Policy’s terms, pursuant to Conn.

Gen. Stat. §42-110g(d).

86. In compliance with Conn. Gen. Stat. §42-110g(c), a copy of this Class Action

Complaint has been mailed to the Attorney General of the State of Connecticut and Connecticut’s

Commissioner of Consumer Protection on this date. A copy has also been submitted to the

Connecticut Insurance Department.

COUNT TWO

VIOLATION OF CONNECTICUT UNFAIR TRADE PRACTICES ACT (“CUTPA”)

THROUGH VIOLATION OF THE CONNECTICUT CORRUPT ORGANIZATIONS
AND RACKETEERING ACTIVITY ACT (“CORA”)
(On Behalf of the Nationwide Class and Minnesota Subclass)

87. Plaintiff repeats, reasserts, and incorporates the allegations contained in paragraphs

1 - 86 as if fully set forth herein.

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88. Cigna has acted, as alleged herein, in the conduct of trade or commerce as defined

in Conn. Gen. Stat. §42-110a(4).

89. As set forth above, Cigna, in violation of CORA, engaged in racketeering activity,

including fraudulently, deceptively, and unfairly scheming to implement an automated system

whereby claims would be automatically denied in violation of state and federal insurance laws in

order to unlawfully enrich themselves at the expense of Plaintiff and the Class in violation of Conn.

Gen. Stat. §53-395(a) and (c).

90. As set forth above, Cigna, in violation of CORA, engaged in a pattern of

racketeering activity, including engaging in at least two incidents of racketeering activity that: (i)

have the same or similar purposes, results, participants, victims, or methods of commission or

otherwise are interrelated by distinguished characteristics; and (ii) are not isolated incidents, all in

violation of Conn. Gen. Stat. §42-110a et seq.

91. Cigna’s violations of CORA are violations of the Connecticut Unfair Trade

Practices Act (“CUTPA”), Conn. Gen. Stat. §42-110b(a), and give rise to a cause of action under

Conn. Gen. Stat. §42-110g(a).

92. Cigna’s conduct is part of a general business practice that constitutes unfair and

deceptive acts in violation of Conn. Gen. Stat. §42-110b(a).

93. As a direct and proximate result of Cigna’s racketeering conspiracy and violations

of CUTPA, Conn. Gen. Stat. §42-110b(a), Plaintiff and the Class members have suffered

ascertainable losses under Conn. Gen. Stat. §42-110g(a) in an amount to be proved at trial.

94. As a result of Cigna’s unfair and/or deceptive acts or practices, Cigna has reaped

ill-gotten profits and gains, which they otherwise would not have received and which, in equity,

they should be required to disgorge.

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Case 3:23-cv-01135-OAW Document 1 Filed 08/25/23 Page 20 of 26

95. Cigna is liable, pursuant to Conn. Gen. Stat. §42-110g(a), for punitive damages.

96. Furthermore, Cigna is liable, pursuant to Conn. Gen. Stat. §42-110g(d), for costs

and reasonable attorneys’ fees.

97. Plaintiff also seeks an injunction on behalf of himself and the Class prohibiting

Cigna from violating CUTPA and/or CORA, and breaching the Policy’s terms, pursuant to Conn.

Gen. Stat. §42-110g(d).

98. In compliance with Conn. Gen. Stat. §42-110g(c), a copy of this Class Action

Complaint has been mailed to the Attorney General of the State of Connecticut and Connecticut’s

Commissioner of Consumer Protection on this date. A copy has also been submitted to the

Connecticut Insurance Department.

COUNT THREE

BREACH OF CONTRACT
(On Behalf of the Nationwide Class and Minnesota Subclass)

99. Plaintiff repeats, reasserts, and incorporates the allegations contained in paragraphs

1-98 as if fully set forth herein.

100. Cigna formed an agreement and entered into a contract of insurance with Plaintiff

and the Class, namely through each policy, including offer, acceptance, and consideration.

101. Pursuant to each policy, Plaintiff and the Class paid money to Cigna in exchange

for Cigna providing benefits under a group insurance policy to Plaintiff and the Class.

102. Each policy included, without limitation, Cigna’s duty to exercise its fiduciary

duties to policyholders, abide by applicable state and federal laws, and adequately review and

inform policyholders prior to a claim denial.

103. Plaintiff and the Class performed their obligations under the contract by paying the

amounts due under the contract timely.

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Case 3:23-cv-01135-OAW Document 1 Filed 08/25/23 Page 21 of 26

104. Cigna breached each policy by, without limitation, failing to keep its promise to

fulfill its duty to exercise its fiduciary duties to policyholders, abide by applicable state and federal

laws, and adequately review and inform policyholders prior to a claim denial.

105. As a direct and proximate result of Cigna’s breach of contract, Plaintiff and the

Class have suffered damages in an amount to be proven at trial.

COUNT FOUR
UNJUST ENRICHMENT
(On Behalf of the Nationwide Class and Minnesota Subclass)

106. Plaintiff repeats, reasserts, and incorporates the allegations contained in paragraphs

1-105 as if fully set forth herein.

107. By delegating the claims review process to the automated PxDx system, Cigna

knowingly charged Plaintiff and the Class members insurance premiums for services that Cigna

failed to deliver. This was done in a manner that was unfair, unconscionable, and oppressive.

108. Cigna knowingly received and retained wrongful benefits and funds from Plaintiff

and the Class members. In so doing, Cigna acted with conscious disregard for the rights of Plaintiff

and the Class members.

109. As a result of Cigna’s wrongful conduct as alleged herein, Cigna has been unjustly

enriched at the expense of, and to the detriment of, Plaintiff and the Class members.

110. Cigna’s unjust enrichment is traceable to and resulted directly and proximately

from the conduct alleged herein.

111. Under the common law doctrine of unjust enrichment, it is inequitable for Cigna to

be permitted to retain the benefits they received (without justification) by arbitrarily denying

medical payments owed to their insureds, under Cigna’s policies, in an unfair, unconscionable,

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Case 3:23-cv-01135-OAW Document 1 Filed 08/25/23 Page 22 of 26

and oppressive manner. Cigna’s retention of funds under such circumstances makes it inequitable

for Cigna to retain those funds and constitutes unjust enrichment.

112. The financial benefits derived by Cigna rightfully belong to Plaintiff and the Class

members. Cigna should be compelled to return, in a common fund for the benefit of Plaintiff and

the Class members, all wrongful or inequitable proceeds received by Cigna.

113. Plaintiff and the members of the Class have no adequate remedy at law.

COUNT FIVE

BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING

(On Behalf of the Nationwide Class and Minnesota Subclass)

114. Plaintiff repeats, reasserts, and incorporates the allegations contained in paragraphs

1-113 as if fully set forth herein.

115. Plaintiff brings this claim for breach of the implied covenant of good faith and fair

dealing against Cigna on behalf of the Class.

116. Plaintiff and the Class members entered into written contracts with Cigna, which

provided coverage for medical services administered by healthcare providers.

117. Pursuant to those contracts, in exchange for insureds’ premium payments, Cigna

implied and covenanted that they would act in good faith and follow the law and the contracts with

respect to the prompt and fair payment of Plaintiff’s and the Class members’ claims.

118. Cigna has breached its duty of good faith and fair dealing by, among other things:

a. improperly delegating their claims review function to the PxDx system,

which uses an automated process to improperly deny claims;

b. allowing their medical directors to sign off on the denials in batches without

individually reviewing each patient’s file; and

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Case 3:23-cv-01135-OAW Document 1 Filed 08/25/23 Page 23 of 26

c. failing to have their medical directors conduct a thorough, fair, and

objective investigation of each submitted claim, such as examining patient

records, reviewing coverage policies, and using their expertise to decide

whether to approve or deny claims to avoid unfair denials.

119. Cigna’s practices as described herein violated their duties to Plaintiff and the Class

members under the insurance contracts.

120. Cigna’s practices as described herein violated their duties to Plaintiff and the Class

members under Connecticut law.

121. Cigna’s practices as described herein constitute an unreasonable denial of

Plaintiff’s and the Class members’ rights to a thorough, fair, and objective investigation of each of

their claims by a doctor and breach the implied covenant of good faith and fair dealing arising

from Cigna’s insurance contracts.

122. Cigna’s practices as described herein further constitute an unreasonable denial to

pay benefits due to Plaintiff and the Class members in breach of the implied covenant of good faith

and fair dealing arising from Cigna’s insurance contracts.

123. Cigna’s wrongful denial of Plaintiff’s and the Class members’ right to a thorough,

fair, and objection investigation and wrongful denial of claims damaged Plaintiff and the Class

members.

124. As a direct and proximate result of Cigna’s breaches, Plaintiff and the Class

members have suffered, and will continue to suffer in the future, economic losses including: the

benefits owed under their health insurance plans; the interruption of Plaintiff’s and the Class

members’ businesses; and other general, incidental, and consequential damages, in amounts

23
Case 3:23-cv-01135-OAW Document 1 Filed 08/25/23 Page 24 of 26

according to proof at trial. Plaintiff and the Class members also seek statutory and pre- and post-

judgment interest against Cigna.

125. Cigna’s misconduct was committed intentionally, in a malicious, fraudulent,

despicable, and oppressive manner, and therefore Plaintiff and the Class members seek punitive

damages against Cigna.

126. By reason of Cigna’s conduct as alleged herein, Plaintiff has necessarily retained

attorneys to prosecute the present action. Plaintiff therefore seeks reasonable attorneys’ fees and

litigation expenses, including expert witness fees and costs incurred in bringing this action.

IX. REQUEST FOR RELIEF

WHEREFORE, Plaintiff prays for judgment and relief in her favor and in favor of the

Class; and against Defendants and that Defendants be cited, according to law, to appear and answer

herein; that after notice and upon final hearing, a PERMANENT INJUNCTION be issued,

restraining and enjoining Defendants, as well as Defendants’ successors, assigns, officers, agents,

servants, employees, attorneys, and any other person in active concert or participation with

Defendants, from engaging in the acts or practices complained of herein. In addition, Plaintiff

respectfully prays that this Court will:

A. Order Defendants to restore all money or other property taken from identifiable

persons by means of unlawful acts or practices and award judgment for damages in an amount

within the jurisdictional limits of this Court to compensate for such losses;

B. Order the disgorgement of all sums unlawfully taken from consumers for the

benefit of Plaintiff and the Class;

C. Certify this action and the Class as requested herein, appointing Plaintiff as Class

Representative and appointing her counsel as Class Counsel;

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Case 3:23-cv-01135-OAW Document 1 Filed 08/25/23 Page 25 of 26

D. Award Plaintiff and the Class members actual damages, plus costs and reasonable

and necessary attorneys’ fees, and any other relief the Court determines is proper, pursuant to

Conn. Gen. Stat. §42-110g(d);

E. Award restitution and disgorgement of Cigna’s revenues to Plaintiff and the Class;

F. Award punitive damages to Plaintiff and Class members, pursuant to Conn. Gen.

Stat. §42-110g(a) and Conn. Gen. Stat. §52-564; and

G. Provide such other and further relief as the Court may deem just and proper.

X. JURY TRIAL DEMANDED

Under Federal Rules of Civil Procedure, Rule 38, Plaintiff demands a trial by jury.

Dated: August 25, 2023 SCOTT+SCOTT ATTORNEYS AT LAW LLP

/s/ Joseph P. Guglielmo

Joseph P. Guglielmo (CT 27481)
Amanda Rolon (Pro hac vice forthcoming)
The Helmsley Building
230 Park Avenue, 17th Floor
New York, NY 10169
Telephone: (212) 223-6444
Facsimile: (212) 223-6334
[email protected]
[email protected]

SCOTT+SCOTT ATTORNEYS AT LAW LLP

Erin Green Comite (CT 24886)
Anja Rusi (CT 30686)
156 South Main Street
P.O. Box 192
Colchester, Connecticut 06415
Tel. (800) 404-7770
[email protected]
[email protected]

CARELLA, BYRNE, CECCHI,

BRODY & AGNELLO, P.C.
James E. Cecchi (Pro hac vice forthcoming)
Michael A. Innes Pro hac vice forthcoming)

25
Case 3:23-cv-01135-OAW Document 1 Filed 08/25/23 Page 26 of 26

Jordan M. Steele Pro hac vice forthcoming)

5 Becker Farm Road
Roseland, New Jersey 07068
Tel.: (973) 994-1700
[email protected]
[email protected]
[email protected]

CARELLA, BYRNE, CECCHI,

BRODY & AGNELLO, P.C.
Zachary S. Bower (Pro hac vice forthcoming)
2222 Ponce De Leon Blvd.
Miami, Florida 33134
Tel.: (973) 994-1700
[email protected]

Attorneys for Plaintiff

26
JS 44 (Rev. 04/21) Case 3:23-cv-01135-OAW
CIVILDocument
COVER 1-1 Filed 08/25/23 Page 1 of 2
SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
Paige Van Pelt, Individually and on Behalf of All Others The Cigna Group, Cigna Corporation, and Cigna Health and
Similarly Situated Life Insurance Company
(b) County of Residence of First Listed Plaintiff Aitkin Cnty, MN County of Residence of First Listed Defendant Hartford Cnty, CT
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Joseph P. Guglielmo
Scott+Scott Attorneys at Law LLP
230 Park Avenue, 17th Floor, New York, NY 10169
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ INTELLECTUAL 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation
Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/
362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION 26 USC 7609 Act/Review or Appeal of
Employment Other: 462 Naturalization Application Agency Decision
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of
Other 550 Civil Rights Actions State Statutes
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
28 U.S.C. §1332(a)
VI. CAUSE OF ACTION Brief description of cause:
Deceptive acts and practices associated with healthcare claims denials
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
August 25, 2023 /s/Joseph P. Guglielmo
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

JS 44 Reverse (Rev. 04/21) Case 3:23-cv-01135-OAW Document 1-1 Filed 08/25/23 Page 2 of 2
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then
the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.

V. Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statute.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service.

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.