Wightman v. Ameritas Life Insurance Corp.

The Fifth Circuit reversed a district court ruling that excluded dental services from Louisiana's Preferred Provider Organization Act. The court held that dentists qualify as healthcare providers under the statute and remanded the case for further proceedings on remaining claims.

Background

The Wightmans, a dental practice, contracted with DenteMax to offer discounted rates to its subscribers. Ameritas Life Insurance Corporation later entered an agreement with DenteMax to reimburse providers at those discounted rates without the Wightmans’ knowledge. When Ameritas refused to reimburse the Wightmans at their standard rates, they sued for violations of Louisiana’s PPO Act and other claims. The district court granted summary judgment to Ameritas, ruling that dental services were not healthcare under the Act and that the Wightmans had abandoned their other claims.

The court’s reasoning

The Fifth Circuit applied Louisiana’s civilian methodology for statutory interpretation, concluding that the broad language of the PPO Act includes dentists as healthcare providers. The court rejected the argument that the Network Leasing Act displaced the PPO Act for dental services, finding the statutes govern different conduct and should be read together. The court also held that the district court lacked authority to determine if claims were abandoned on appeal and abused its discretion by applying judicial estoppel without proper analysis.

We conclude that dental services are healthcare under the PPO Act for two reasons. First, the Act’s broad language and healthcare’s historical usage suggest that dentists are covered under the Act.

Wightman v. Ameritas Life Ins. Corp., No. 24-30775 (5th Cir. June 12, 2026)

What it means going forward

Insurance companies must now recognize dentists as covered providers under Louisiana’s PPO Act when issuing benefit cards, and district courts must reconsider abandoned claims and judicial estoppel arguments on remand.