Mealey's (June 9, 2020, 10:04 AM EDT) -- SAN FRANCISCO — The Ninth Circuit U.S. Court of Appeals on May 19 affirmed the sua sponte dismissal of a surgical center’s Employee Retirement Income Security Act action alleging that United Healthcare Services Inc. owes approximately $1.7 million in surgery bills because the complaint was too general (Glendale Outpatient Surgery Center v. United Healthcare Services, Inc., et al., No 19-55142, 9th Cir.)....