On June 9, the U.S. District Court for the District of Utah denied certification to a class of United Healthcare Insurance Co. members who alleged that United wrongly failed to cover wilderness therapy for troubled teenagers. According to the court, Plaintiffs failed to demonstrate commonality or satisfy any of Rule 23(b)’s requirements. Plaintiffs could not demonstrate a uniform policy because some claims were denied on the grounds that wilderness therapy is experimental and investigational, others were denied on medical necessity grounds, and one was paid in full.