A Delaware court has denied a motion to dismiss a breach of contract lawsuit between Midwest Integrated Care LLC and Health Management Associates, Inc. The ruling, issued on August 10, 2026, allows the case to proceed in Delaware, impacting both companies involved in the healthcare sector.
The dispute centers around a Master Services Agreement (MSA) between the two companies, with Midwest alleging that HMA failed to fulfill its contractual obligations. HMA countered that Midwest had not paid its outstanding bills, leading to the legal action. The court's decision is significant as it determines where the case will be litigated, potentially influencing the outcome of the ongoing business relationship between the two parties.
Background
Midwest Integrated Care, founded in February 2025, is an Ohio-based healthcare startup focused on providing integrated outpatient behavioral health services. The company engaged HMA, a Michigan corporation, to assist with administrative and regulatory requirements in the medical field. However, tensions arose as Midwest expressed dissatisfaction with HMA's performance, claiming breaches of the MSA.
In December 2025, HMA filed a breach of contract complaint in Michigan, seeking payment for services rendered. Just a day later, Midwest filed a lawsuit in Delaware, seeking a declaratory judgment that it was not in breach of the MSA. This led HMA to file a motion to dismiss the Delaware action, arguing that the case should be heard in Michigan instead.
The Ruling
The Delaware Superior Court, presided over by Judge Sheldon K. Rennie, ruled against HMA's motion to dismiss based on the doctrine of forum non conveniens. This legal principle allows a court to dismiss a case if another jurisdiction is more appropriate for the litigation. However, the court found that HMA did not demonstrate that Delaware was an inconvenient forum.
The court ruled, "HMA has failed to establish that litigating in Delaware poses an inconvenience sufficient to warrant dismissal or a stay."
Judge Rennie noted that the case's procedural posture and the ongoing discovery process in Delaware weighed against HMA's motion. The court also highlighted that both parties had significant connections to their respective states, but neither party was a Delaware entity.
Impact
This ruling is crucial for both Midwest and HMA as it allows the Delaware court to retain jurisdiction over the case. The decision means that the legal proceedings will continue in Delaware, where Midwest has already begun the discovery process. The court's analysis of the Cryo-Maid factors, which assess the appropriateness of the forum, suggests that the balance of convenience does not heavily favor Michigan.
The ruling may also set a precedent for similar business disputes involving forum non conveniens motions in Delaware. By denying HMA's motion, the court reinforces the principle that plaintiffs' choices of forum are given significant weight, especially when the case has already progressed in that jurisdiction.
What's Next
With the motion to dismiss denied, the case will continue to move forward in Delaware. HMA may still have options to appeal the decision if they believe there are grounds to challenge the court's ruling. Meanwhile, both parties will prepare for the next stages of litigation as they seek to resolve their contractual disputes.











