PHI Air Medical, LLC v. Texas Mutual Insurance Company, Hartford Underwriters Insurance Company, TASB Risk Management Fund, Transportation Insurance Company, Truck Insurance Exchange, Twin City Fire Insurance Company, Valley Forge Insurance Company
This letter serves as a reply from Insurer Appellees Texas Mutual Insurance Company, et al. to the Third District Court of Appeals. It addresses arguments made by PHI Air Medical, LLC regarding the definition of the 'business of insurance' under the McCarran-Ferguson Act, particularly concerning payments made to third parties versus directly to insureds. The Insurers contend that PHI's proposed distinction lacks common sense and is contrary to established Supreme Court authority, citing cases such as U.S. Treasury v. Fabe. They argue that the actual performance of an insurance contract, including paying medical benefits to providers, is an essential part of the 'business of insurance' and that state laws prescribing contract terms directly regulate this business. The letter concludes by asserting that PHI’s arguments are inconsistent with both the practical workings of insurance and Supreme Court precedent.