In Worldwide Aircraft Services Inc. v. Anthem Insurance Companies Inc., the U.S. District Court for the Middle District of Florida addressed a motion to dismiss filed on behalf of defendant Anthem BCBS to dismiss a petition to confirm an arbitration award based on several grounds, including lack of personal jurisdiction.
Jet ICU, located in Tampa, provided emergency air ambulance services to an individual insured by Anthem BCBS and filed a claim with BCBS Federal Program Overseas Claims for the services it provided. A billing dispute arose regarding the proper payment amount and Jet ICU filed an arbitration or independent dispute resolution proceeding against BCBS Federal Program Overseas Claims under the No Surprises Act, 42 U.S.C. § 300gg-112. After the arbitrator determined the appropriate payment due for the services and entered an award for Jet ICU, Jet ICU filed a petition to confirm arbitration award naming Anthem BCBS as the respondent. Anthem BCBS then filed a motion to dismiss the petition arguing, among other points, a lack of personal jurisdiction. In support of its contention that the court lacked personal jurisdiction over it, Anthem BCBS submitted a declaration “negating the existence of any substantial connection … to Florida” including that Anthem BCBS is an Indiana corporation with a principal place of business in Indiana, does not fund or administer claims in Florida, does not maintain an office or phone contact in Florida, and does not advertise or solicit business in Florida.
The court found that the evidence submitted by Jet ICU in opposition to Anthem BCBS’ jurisdictional arguments did not establish personal jurisdiction over Anthem. Noting that due process requires that a defendant “by its own actions create the required minimum contacts with the forum state,” the court found that Jet ICU’s petition to confirm the arbitration award did not provide sufficient evidence to support the assertion of personal jurisdiction over Anthem BCBS under Florida’s long-arm statute or the due process clause of the U.S. Constitution. The court granted Anthem BCBS’ motion and dismissed the petition without prejudice.
Worldwide Aircraft Services, Inc. v. Anthem Insurance Companies, Inc., No. 8: 25-cv-01444 (M.D. Fla. Dec. 31, 2025).
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