Prichard v. Metro. Life Ins. Co.

After a series of unsuccessful appeals to an ERISA plan administrator after the administrator’s decision to deny him long-term disability benefits, Plaintiff brought this action under 29 U.S.C. 1132(a)(1)(B). The district court affirmed. The Ninth Circuit vacated the district court’s judgment, holding that the district court erred in reviewing the denial of benefits for an abuse of discretion, rather than de novo, when a Summary Plan Description conferred discretionary authority upon the plan administrator but an insurance certificate, a governing plan document, did not. Remanded for the district court to review the plan administrator’s denial of benefits de novo. View "Prichard v. Metro. Life Ins. Co." on Justia Law