Worldwide Aircraft Services, Inc. v. United Healthcare
Trial Court Opinion
UMNIIDTEDDL ES TDAISTTERS IDCITS TORFI FCLTO CROIDUART TAMPA DIVISION WORLDWIDE AIRCRAFT SERVICES, INC., Petitioner, v. CASE NO. 8:25-cv-01225-SDM-SPH UNITED HEALTHCARE, Respondent. ___________________________________/
ORDER In 2024, Worldwide Aircraft Services, Inc., requested Independent Dis- pute Resolution (IDR) under the No Surprises Act and obtained an award of $21,572.25 against United Healthcare. (Doc. 1-2). 42 U.S.C. §§ 300gg- 111(c)(2)(A), 300gg-112(b)(1)(B). The petitioner moves (Doc. 1) to confirm the award against the respondent, who moves (Doc. 16) to dismiss the petition for lack of subject-matter jurisdiction. No response appears.
An earlier action brought by the same petitioner against the same re- spondent and requesting confirmation of an IDR award granted under the same statute was dismissed for lack of subject-matter jurisdiction. Worldwide Aircraft Servs., Inc. v. United Healthcare, No. 8:24-CV-2527-TPB-LSG, 2025 WL 3312169 (M.D. Fla. Nov. 28, 2025). Another action brought by the same peti- tioner against a different insurance company was dismissed for the same reason. Worldwide Aircraft Servs., Inc. v. United Healthcare, No. 8:25-cv-01158- WFJ-AEP, 2025 WL 3551397 (M.D. Fla. Dec. 11, 2025).
The motion to dismiss is GRANTED and the action is DISMISSED WITH PREJUDICE because, as held in the other two actions, “the NSA’s IDR provisions do not give rise to a federal cause of action and... IDR awards are not enforceable under the FAA.” Worldwide, 2025 WL 3312169, at *2. The petitioner cites no fact distinguishing the present action and cites no authority challenging the earlier holdings. Accordingly, no later than FEBRU- ARY 27, 2026, in a paper no longer than seven pages, the plaintiff must SHOW CAUSE why a sanction should not issue under Rule 11(c)(3), Federal Rules of Civil Procedure, for presenting a claim not “warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing ex- isting law or for establishing new law.” Rule 11(b)(2), Federal Rules of Civil Procedure. The clerk must ADMINISTRATIVELY CLOSE the case.
ORDERED in Tampa, Florida, on February 13, 2026.
Asdornnsgig STEVEN D. MERRYDAY UNITED STATES DISTRICT JUDGE -2-
Case-law data current through December 31, 2025. Source: CourtListener bulk data.