The Nevada Supreme Court handed down a key decision on June 12, 2025, resolving a multiyear dispute between UnitedHealthcare and emergency care provider TeamHealth over out-of-network reimbursements. The ruling narrows a major jury verdict while clarifying how insurers must handle payments for emergency services when no formal contract is in place.
The conflict stems from a breakdown in negotiations between the two companies. When TeamHealth's contract with UnitedHealthcare expired in mid-2017, the provider continued treating UnitedHealthcare members in Nevada hospitals. Over the following three and a half years, TeamHealth submitted more than 75,000 claims. Of those, roughly 11,500 were disputed, with TeamHealth alleging it received just $2.84 million in reimbursement on $13.24 million in billed charges.
A jury sided with TeamHealth in 2022, awarding $2.65 million in compensatory damages and an eye-popping $60 million in punitive damages. The trial court also tacked on penalties and legal fees under Nevada’s Prompt Pay Act and Unfair Claims Practices Act. UnitedHealthcare appealed.
The Nevada high court upheld the jury's core finding—that UnitedHealthcare had been unjustly enriched by benefiting from TeamHealth's emergency services while underpaying. Importantly, TeamHealth had not attempted to collect the difference from patients, a practice known as balance billing. The court said that created a financial benefit for UnitedHealthcare, which was able to meet its obligations to members while keeping payments low.
However, the justices also scaled back the overall judgment significantly. They ruled there was no implied contract between the two sides, since negotiations had failed and no agreement had been reached. They also tossed out the statutory claims, noting that Nevada’s insurance laws didn’t give TeamHealth a private right to sue under those provisions.
And while the court agreed punitive damages were warranted, it said the $60 million figure was too high. The justices sent the case back to the lower court to reduce the award to no more than the amount of compensatory damages—a 1:1 ratio in line with state and federal due process rules.
In a separate matter, the court rejected UnitedHealthcare’s attempt to seal certain internal documents introduced during trial, including business strategies and pricing models. The insurer had failed to properly object at the time, the court said, and didn’t meet the burden for keeping trial records confidential.
Although the ruling didn’t involve interpretation of any specific policy language, it offers a cautionary note for insurers on how courts may handle out-of-network payment disputes—particularly when emergency care is involved and no contract governs the reimbursement process.
The decision underscores the operational and legal risks carriers face when provider agreements lapse, and highlights the importance of clear payment practices and documentation, even outside formal contracts. For insurers, it’s a reminder that how they respond in these grey areas could ultimately end up before a jury—or the state's highest court.
