State Of Louisiana v. Optumrx, Inc. And United Healthcare Of Louisiana, Inc. D/b/a United Healthcare Community Plan

Supreme Court of Louisiana
November 12, 2025
Chief Deputy Clerk of Court
For the Court
The Supreme Court of the State of Louisiana
STATE OF LOUISIANA
VS.
OPTUMRX, INC. AND UNITED
HEALTHCARE OF LOUISIANA, INC. D/B/A
UNITED HEALTHCARE COMMUNITY PLAN
No. 2025-C-00911
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I
N RE: State of Louisiana - Applicant Plaintiff; Applying For Writ Of Certiorari,
Parish of East Baton Rouge, 19th Judicial District Court Number(s) C- 717,848,
Court of Appeal, First Circuit, Number(s) 2024 CA 0596;
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November 12, 2025
Writ application granted. See per curiam.
C
rain, J., recused.
JDH
JLW
JBM
PDG
JMG
CRC
11/12/2025 "See News Release 050 for any Concurrences and/or Dissents."

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SUPREME COURT OF LOUISIANA
No. 2025-C-911
STATE OF LOUISIANA
VS.
OPTUMRX, INC. AND UNITED HEALTHCARE OF LOUISIANA, INC.
D/B/A UNITED HEALTHCARE COMMUNITY PLAN
On Writ of Certiorari to the Court of Appeal, First Circuit,
Parish of East Baton Rouge
PER CURIAM
Writ granted. A judgment was rendered by the district court in this matter on
March 13, 2023 (the Discovery Judgment), granting a motion to compel delinquent
discovery filed by the State of Louisiana against United Healthcare of Louisiana,
Inc. and OptumRx, Inc. (collectively, United .) Therein, the district court specified
what records United was required to produce , as well as the applicable deadlines.
The Discovery Judgment further specifically found that the requested documents,
including certain out-of-state documents, were relevant to this litigation and must be
produced in unredacted form. United sought review of the Discovery Judgment with
the First Circuit Court of Appeal, as well as with the Louisiana Supreme Court, but
both courts denied writs. See State v. OptumRx , Inc., 23 -272 (La. App. 1 Cir.
3/23/23), 2023 WL 2609637, writ denied, 23-474 (La. 5/2/23), 360 So.3d 12.
Thereafter, on August 3, 2023, the trial court rendered a judgment (the
Sanctions Judgment), granting a motion for sanctions and attorneys’ fees that was
filed by the State as a result of United having yet to fully comply with the Discovery
Judgment. Following a hearing, the amount of the awarded attorneys’ fees was set
forth in a judgment rendered on October 9, 2023 (the Attorneys’ Fee Judgment).
United sought review of the Sanctions Judgment and the Attorneys’ Fee
Judgment. On appeal, the First Circuit Court of Appeal reversed, in part, both the

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Discovery and Sanctions Judgments and vacated the Attorneys’ Fee Judgment.
Specifically, the court of appeal found that the district court abused its discretion
when it found that the requested out-of-state records were relevant and should be
produced, and when it sanctioned United for its failure to produce certain other
records that were ordered to be produced pursuant to the Discovery Judgment .
Additionally, the court of appeal concluded that, in finding that United violated the
Discovery Judgment by placing a watermark across the records that were produced,
the district court committed manifest error. The court of appeal further found that
numerous other factual findings of the district court were manifestly erroneous
and/or clearly wrong. Based on these findings the appellate court reversed, in part,
both the Discovery and Sanctions Judgments, and vacated the Attorneys’ Fee
Judgment.
The court of appeal correctly noted that , with regard to the many issues that
involve questions of fact, the appropriate standard of review is the manifest error -
clearly wrong standard, pursuant to which an appellate court cannot set aside a
district court's finding of fact unless the finding is “clearly wrong” in light of the
record reviewed in its entirety. (“The court must review the entire record… .”)
Hayes Fund for First United Methodist Church of Welsh, LLC v. Kerr-McGee
Rocky Mountain, LLC , 14-2592, p. 8 (La. 12/8/15), 193 So.3d 1110, 1115. To
reverse a district court’s factual finding, a court of appeal must find that there is no
reasonable factual basis in the record to support the finding, such that it is “clearly
wrong.” See Stobart v. State through Dept. of Transp. &, Dev. , 617 So. 2d 880,
882 (La. 1993). This requires more than reviewing the record for some evidence
supporting or controverting the district court ’s finding. Id. The manifest error -
clearly wrong standard is therefore not easily met, as it is rare that no reasonable
basis exists to support a finding of a district court. See Hayes, 193 So. 3d at 1116;
Johnston v. Vincent , 21-1196 (La. 2/1/23 ), 359 So.3d 896, 911 . Although the

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appellate court acknowledged that the manifest error -clearly wrong standard of
review was applicable to the district court’s factual findings in this case, it
nevertheless failed to apply that standard. Specifically, rather than conducting a
review of the record to determine if any reasonable factual basis to support the
findings existed, the appellate court stated in its opinion that, “[t]his [c]ourt is not
required to sift through the record to unearth a reasonable factual basis for the trial
court's factual findings.” Instead, the court of appeal noted that United pointed to
evidence in the record “refuting” the trial court’s factual findings and the State failed
to provide the court with record references to any supporting evidence.
Moreover, the court of appeal further found the district court’s determination
that certain documents were relevant to be an abuse of discretion. As noted by the
dissent, the appellate court reversed the district court finding without any sort of
review of the disputed documents and despite the fact that the trial court, which has
presided over these parties and this litigation for many years, specifically found that
the documents were discoverable. In any event, th e district court’s relevancy
determination was set forth in its Discovery Judgment, for which United previously
sought, and was denied, relief by both the First Circuit Court of Appeal and the
Louisiana Supreme Court. As such, this issue was not properly before the appellate
court for review. Rather, review is limited to the Sanctions Judgment and the
Attorneys’ Fee Judgment. The appellate court’s rulings are vacated and this matter
is remanded to the court of appeal to reconsider the Sanctions Judgment and the
Attorneys’ Fee Judgment following a thorough review of the record in its entirety,
as is required for a proper application of the manifest error -clearly wrong standard
of review.
WRIT GRANTED; RULINGS VACATED; and REMANDED.