Law360, New York (May 23, 2016, 11:08 AM ET) -- In Patel v. Allstate New Jersey Insurance Co., No. 15-2513 (3d Cir. May 3, 2016), the Third Circuit affirmed the dismissal of constitutional claims brought by a medical doctor alleging that the New Jersey attorney general and the Office of the New Jersey Insurance Fraud Prosecutor had improperly outsourced criminal investigations to the special investigative units of several insurance companies. The court found that the plaintiff lacked standing because he had not alleged "that there is - or ever was - a criminal investigation or prosecution against him." Id., Slip op. at 6. Accordingly, plaintiff could not "demonstrate the requisite injury to support constitutional standing." Id., at 7.
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