alleged
Jackie Martin, Tennessee: estate alleges UnitedHealth's nH Predict algorithm cut off care before his death
Jackie Martin, a UnitedHealthcare Medicare Advantage member, was admitted to a skilled nursing facility after fracturing his back in April 2023. According to the First Amended Complaint in Estate of Gene B. Lokken et al. v. UnitedHealth Group, UnitedHealthcare issued four notices ending his coverage in May 2023; two of them were reversed on appeal. After the fourth, he went home on May 19, 2023, and died on May 23, 2023. His estate alleges the denials were driven by the nH Predict AI model and that they 'denied Mr. Martin the chance to fully recover, leading to his death.' UnitedHealth disputes the claims and says nH Predict is not used to make coverage decisions.
- Status
- Alleged, not proven
- Deaths
- 1
- Date
- 23 May 2023
- Place
- Tennessee, United States
- AI system
- nH Predict (naviHealth post-acute care length-of-stay prediction tool)
- Developer / operator
- naviHealth (UnitedHealth Group subsidiary)
- Named
- Jackie Martin
Why this case is “alleged”
No court, coroner or official investigation has yet found that nH Predict (naviHealth post-acute care length-of-stay prediction tool) caused or contributed to this death. The case is listed because it meets our standard for a credible allegation. It will move to the confirmed count only if an official body makes such a finding.
Legal status
Estate of Gene B. Lokken et al. v. UnitedHealth Group, Inc. et al., No. 0:23-cv-03514 (D. Minn.). The original complaint was filed 14 November 2023. The Estate of Jackie Martin was added as a plaintiff in the First Amended Complaint on 5 April 2024. On 13 February 2025 Judge John R. Tunheim granted the motion to dismiss in part and denied it in part: most state-law claims were held preempted, but the breach-of-contract and implied-covenant claims proceed. On 9 March 2026 the magistrate judge ruled on plaintiffs' motion to compel discovery. The case was still in discovery as of 11 September 2026 (defendants filed a second amended answer on 4 September 2026). No class has been certified, and no court has made any finding on causation or liability.
Notes
Causation, and nH Predict's role in his specific denials, are contested, and the court has made no findings. Whether nH Predict uses machine learning hasn't been disclosed; the complaint calls it an AI model. Other named plaintiffs in the same suit, including Gene Lokken, have died, but the complaint doesn't allege the denials caused their deaths, so they aren't counted.
Sources
- First Amended Class Action Complaint, Estate of Gene B. Lokken et al. v. UnitedHealth Group
- Memorandum Opinion and Order on Motion to Dismiss
- Order on Plaintiffs' Motion to Compel Discovery
- UnitedHealth pushed employees to follow an algorithm to cut off Medicare patients' rehab care
- Estate of Gene B. Lokken, The v. UnitedHealth Group, Inc., 0:23-cv-03514