Patel v. Crist, 2020 U.S. Dist. LEXIS 2111

Claims under the Insurance Fraud Prevention Act cannot be supported by generalized, abstract grievances shared by a large number of similarly situated people.

Allstate Insurance Company, the State of New Jersey, Office of the New Jersey Attorney General, Office of the Commissioner of the New Jersey Department of Banking and Insurance, and Office of the Insurance Fraud Prosecutor filed a motion to dismiss against two medical providers who filed claims against the defendants under the New Jersey Insurance Fraud Prevention Act (IFPA). The plaintiffs claimed there was harm to the public and various unnamed health care professionals because the plaintiffs were denied exculpatory evidence, were subject to “verbal abuse and harassment from corrupted state court judges,” and had their medical licenses “illegally revoked.” The harm was discussed in a single sentence in the complaint. The court found that vague and unsubstantiated allegations are not sufficient to establish that the plaintiffs suffered an injury-in-fact as a result of the IFPA.


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