Frequently Asked Questions

1. Why is a notice available?

The Settlement would resolve the class action lawsuit Ms. Kruzel filed against Defendants. Please read the Notice and this website carefully. It explains the class action lawsuit, the Settlement, and legal rights you may have, including the process for receiving a Settlement payment, excluding yourself from the Settlement, or objecting to the Settlement.

2. What is the class action about?

Ms. Kruzel filed a class action lawsuit against Defendants alleging that Defendants violated the TCPA by placing, or causing to be placed, certain calls to cellular telephones in connection with which Defendants used, or caused to be used, an artificial or prerecorded voice absent prior express consent, related to one of Defendants’ plans or accounts that is not, or was not, her own plan or account. The TCPA allows for damages in the amount of $500.00 per violation, and up to $1,500.00 for willful or knowing violations. However, prior express consent is a complete defense to a claim under the TCPA. You can find additional information about Ms. Kruzel’s claims in her class action complaint, which is available in the Court Documents section of the Important Documents page.

3. Why is this a class action?

In a class action, one or more people called “Class Representatives” file a class action lawsuit on behalf of people who have similar claims. All of these people together are a “Class” or “Class Members.” The Court accordingly resolves claims for all Class Members at once, except for those who first exclude themselves from the class.

4. Why is there a settlement?

Ms. Kruzel, on the one hand, and Defendants, on the other, have agreed to settle the class action lawsuit to avoid the time, risk, and expense associated with it, and to achieve a final resolution of the disputed claims. Under the Settlement, Settlement Class Members will obtain a payment in settlement of the claims Ms. Kruzel raised in the class action lawsuit. Ms. Kruzel and her attorneys think the Settlement is fair and reasonable.

5. How do you know if your claims are included in the Settlement?

The Settlement resolves claims on behalf of the following Settlement Class:

All persons throughout the United States (1) to whom Molina Healthcare, Inc. or Molina Healthcare of California placed, or Icario, Inc. placed on behalf of Molina Healthcare, Inc. or Molina Healthcare of California, a call, (2) directed to a number assigned to a cellular telephone, but not assigned to a person who has or had an account or plan with Molina Healthcare, Inc. or Molina Healthcare of California, (3) which Molina Healthcare, Inc., Molina Healthcare of California or Icario, Inc. dispositioned as Wrong Number in its records and is one of the numbers that appears in either MOLINA_006055 or ICARIO000017, (4) in connection with which Molina Healthcare, Inc., or Molina Healthcare of California or Icario, Inc. used an artificial or prerecorded voice, (5) from May 30, 2021 through April 21, 2026.

6. What does the Settlement provide?

Defendants will establish a non-reversionary Settlement Fund in the amount of $1,927,500.00 to compensate members of the Settlement Class. Out of the Settlement Fund will be paid:

1. Settlement compensation to approved, participating Settlement Class Members;

2. Notice and administration costs not to exceed $45,000.00;

3. An award of attorneys’ fees not to exceed one-third of the Settlement Fund, subject to the Court’s approval;

4. Litigation costs and expenses incurred in litigating the TCPA claims in this matter not to exceed $35,000.00, subject to the Court’s approval; and

5. An incentive award to Ms. Kruzel not to exceed $12,500.00, subject to the Court’s approval.

Each member of the Settlement Class who submits an approved claim form will be entitled, subject to the provisions of the Settlement Agreement, to his or her equal share of the $1,927,500.00 Settlement Fund as it exists after deducting:

1. Notice and administration costs (including related taxes and expenses);

2. An award of attorneys’ fees;

3. Litigation costs and expenses incurred in litigating the claims in this matter; and

4. An incentive award to Ms. Kruzel.

It is estimated that each participating and approved member of the Settlement Class will receive between $319.00 and $638.00. The actual amount each participating and approved member of the Settlement Class will receive may be more or less depending on the number of participating Settlement Class members who submit timely, valid, and approved claims.

7. How can you get a payment?

You must submit a valid claim form to the Settlement Administrator. There are two ways you can do this:

1. By Mailing a Claim Form: If you received a postcard notice and claim form in the mail, you may mail a valid claim form to:

   Kruzel v. Molina Healthcare, Inc., et al.
   Settlement Administrator,
   P.O. Box 25226
   Santa Ana, CA, 92799

   If you mail your claim form, it must be postmarked by July 6, 2026.

2. By Submitting a Claim Form Online: You may submit a valid claim online here. If you choose to submit a valid claim online, you must do so by July 6, 2026.

If you did not receive a postcard notice and claim form in the mail you may request a postcard notice and claim form by writing to:

Kruzel v. Molina Healthcare, Inc., et al.
Settlement Administrator,
P.O. Box 25226
Santa Ana, CA, 92799

To obtain a Claim Form, you must provide the Settlement Administrator with a telephone number on which you received an artificial or prerecorded voice call from Defendants, or from Icario, Inc. on behalf of Defendants, during the Settlement Class Period. The Settlement Administrator will then confirm that said telephone number appears in MOLINA_006055 or ICARIO000017 before providing the Claim Form to you. If you receive a claim form in this manner, you must complete and return the claim form postmarked by July 6, 2026 to participate in the settlement.

8. When will you be paid?

If the Court grants final approval of the Settlement, Settlement payments will be sent to approved Settlement Class Members who timely mailed or submitted approved claim forms no later than thirty days after the judgment in the lawsuit becomes final. If there is an appeal of the Settlement, payment may be delayed.

9. What rights are you giving up in connection with this Settlement?

If you fall within the Settlement Class, and unless you exclude yourself from the Settlement, you will give up your right to sue or continue a lawsuit against Defendants and related entities over the released claims. Giving up your legal claims is called a release. If you fall within the Settlement Class, unless you formally exclude yourself from the Settlement, you will release certain TCPA-related claims you may have against Defendants and related entities.

For more information about the release, released parties, and released claims, you may obtain a copy of the class action Settlement Agreement here, or from the Clerk of the United States District Court for the District of Oregon.

10. How can you exclude yourself from the Settlement?

If you fall within the Settlement Class, you may exclude yourself from the Settlement, in which case you will not receive a payment, and you will not release any TCPA-related claims you may have against Defendants and related entities. If you fall within the Settlement Class, and if you wish to exclude yourself from the Settlement, you must mail a written request for exclusion to the Settlement Administrator at the following address, postmarked by July 6, 2026:

Kruzel v. Molina Healthcare, Inc., et al.
Settlement Administrator
ATTN: EXCLUSION REQUEST
P.O. Box 25226
Santa Ana, CA, 92799

You must include in your request for exclusion your:

1. Full name;

2. Address;

3. Telephone number to which MHI or MHC placed, or caused to be placed, an artificial or prerecorded voice call from May 30, 2021, through April 21, 2026, to demonstrate you are a member of the Settlement Class; and

4. A clear and unambiguous statement that you wish to be excluded from the Settlement, such as “I request to be excluded from the Settlement in the Kruzel v. Molina Healthcare, Inc., et al. action.”

You must sign the request personally. If any person signs on your behalf, that person must attach a copy of a valid power of attorney authorizing that person to sign on your behalf.

11. When and where will the Court decide whether to approve the Settlement?

The Court will hold a final fairness hearing on August 17, 2026, at 10:00 a.m. PDT. The hearing will take place by telephone. At the final fairness hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate and, if so, whether final approval of the Settlement should be granted. The Court will also hear objections to the Settlement, if any. The Court may make a decision at that time, postpone a decision, or continue the hearing.

The date of the final fairness hearing may change without further notice. Settlement Class Members should check this website, or the Court’s Public Access to Court Electronic Records (“PACER”) site to confirm that the date has not changed.

12. Do you have to attend the final fairness hearing?

No, there is no requirement that you attend the final fairness hearing. However, you are welcome to attend the hearing at your own expense. You cannot speak at the hearing if you have excluded yourself from the Settlement Class because the Settlement no longer affects your legal rights.

13. What if you want to object to the Settlement?

If you fall within the Settlement Class, and if you do not exclude yourself from the Settlement Class, you can object to the Settlement, or any part of it, if you do not believe it is fair, reasonable, and adequate. If you fall within the Settlement Class, and if you wish to object to the Settlement, you must mail a written notice of objection, postmarked by July 6, 2026, to Class Counsel, Counsel for Defendants, and to the Court, at the following addresses:

You must include in your objection your:

1. Full name;

2. Address;

3. Telephone number to which MHI or MHC placed, or caused to be placed, an artificial or prerecorded voice call from May 30, 2021, through April 21, 2026, to demonstrate you are a member of the Settlement Class;

4. A statement of the objection;

5. A description of the facts underlying the objection;

6. A description of the legal authorities that support each objection;

7. A statement noting whether you intend to appear at the Fairness Hearing, either with or without counsel;

8. A list of all witnesses that you intend to call by live testimony, deposition testimony, or affidavit or declaration testimony;

9. A list of exhibits that you intend to present at the Fairness Hearing; and

10. Your signature.

You can ask the Court to deny approval of the Settlement by filing an objection. However, you cannot ask the Court to order a different settlement. The Court can only approve or reject the Settlement. If the Court denies approval, no Settlement payments will be sent out and the class action lawsuit will continue. If that is what you want to happen, you must object.

Any objection to the proposed Settlement must be in writing. If you fall within the Settlement Class, and if you file a timely written objection, you may, but are not required to, appear at the final fairness hearing. If you appear through an attorney, you are responsible for hiring and paying that attorney.

If you file an objection, the parties may seek additional information from you and may also compel you to sit for a deposition. If you fail to file and serve your objection as specified above, you may be deemed to have waived your objection, whether by appeal or otherwise.

14. By when must you enter an appearance?

Any Settlement Class Member who objects to the Settlement and wishes to enter an appearance must do so by July 6, 2026. To enter an appearance, you must file with the Clerk of the Court a written notice of your appearance and you must serve a copy of that notice, by U.S. mail or hand-delivery, upon Class Counsel and Counsel for Defendants, at the addresses in FAQ 13.

15. What if you do nothing?

If you are a member of the Settlement Class, you do nothing, and the Court approves the Settlement Agreement, you will not receive a share of the Settlement Fund, but you will release certain TCPA-related claims you may have against Defendants and related entities. If you fall within the Settlement Class, unless you exclude yourself from the Settlement, you will not be able to sue or continue a lawsuit against Defendants and related entities over the released TCPA claims.

16. What will happen if the Court does not approve the Settlement?

If the Court does not finally approve the Settlement, or if it finally approves the Settlement and the approval is reversed on appeal, or if the Settlement does not become final for some other reason, you will receive no benefits from the Settlement and the class action lawsuit will continue.

17. Who are Ms. Kruzel’s attorneys?

Ms. Kruzel’s attorneys are:

The Court has appointed Ms. Kruzel’s attorneys to act as Class Counsel. You do not have to pay Class Counsel. If you want to be represented by your own lawyer, and have that lawyer appear in court for you in this case, you must hire one at your own expense.

18. Who is Defendants’ attorney?

Defendants’ attorney is:

Hector R. Chavez III
Steptoe LLP
717 Texas Avenue, Suite 2800
Houston, TX 77002-2761

19. Before what court is this matter pending?

Ms. Kruzel filed her class action lawsuit in the following court:

United States District Court for the District of Oregon
Wayne L. Morse U.S. Courthouse
405 East Eighth Avenue
Eugene, OR 97401

20. Where can you get additional information?

This website and the Notice are a summary of the proposed Settlement. For the precise terms and conditions of the Settlement, please see the Settlement Agreement here, by contacting Class Counsel, by accessing the court docket in this case, for a fee, through the Court’s PACER system, or by visiting the office of the Clerk of the Court for the United States District Court for the District of Oregon.

Please do not call the Judge about this class action. Neither the Judge, nor any court personnel, will be able to give you advice about this class action. Furthermore, because neither Defendants nor Defendants’ attorneys represent you, they cannot give you legal advice about this class action.