Linn v. BCBSM, Inc.

905 N.W.2d 497 (2018)

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Linn v. BCBSM, Inc.

Minnesota Supreme Court
905 N.W.2d 497 (2018)

  • Written by Rose VanHofwegen, JD

Facts

James Linn (plaintiff) had health insurance through BCBSM, Inc. (Blue Cross) (defendant) when diagnosed with cancer in the thoracic region of his spine. His doctor recommended proton-beam radiation treatment (PBRT), but Blue Cross denied coverage because the policy said PBRT was medically necessary only if used in certain other regions of the spine, not the thoracic region. The policy explained that Blue Cross considered PBRT in other areas investigative because of a lack of evidence showing it improved health outcomes, and the policy emphasized the type of tumor and location in every policy section that defined whether PBRT would be considered medically necessary. Linn requested an external review as required by Minnesota law. Meanwhile, Linn underwent a series of surgeries to remove the cancer. After the review found PBRT medically necessary, Blue Cross paid for the treatment. Linn and his wife (plaintiff) nonetheless sued, claiming surgery would have been unnecessary had Blue Cross initially approved the treatment. The court granted summary judgment for Blue Cross, and the Linns appealed.

Rule of Law

Issue

Holding and Reasoning (Hudson, J.)

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