Justia U.S. 9th Circuit Court of Appeals Opinion Summaries

Plaintiff filed suit against National Union under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., which permits a beneficiary of an employee benefit plan to bring a civil action to recover benefits owed under the plan. Plaintiff claimed that her husband's death occurred as a result of an accident as defined by the policy. Plaintiff's husband died as a result of Deep Vein Thrombosis (DVT) shortly after he completed roughly 28 hours of air travel in a five-day period. The court concluded that regardless of whether the husband's death may be characterized as an externally caused “accident” when considering that word in isolation, his loss of life was not within the policy’s coverage. His fatal injury did not directly result from an unintended and unanticipated happening “external to the body.” Accordingly, the court affirmed the district court's grant of summary judgment for National Union. View "Williams v. Nat'l Union Fire Ins." on Justia Law

Plaintiff filed suit against AETNA under the civil enforcement provision of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132. AETNA had denied plaintiff's application for continued long-term disability benefits and allowed plaintiff to file an internal appeal within 180 days. The district court dismissed the action for failure to exhaust administrative remedies. The court reversed, holding that because the last day of the appeal period fell on a Saturday, neither that day nor Sunday count in the computation of the 180 days. In this case, because plaintiff mailed his notice of appeal on Monday, it was timely. The court concluded that this method of counting time is widely recognized and furthers the goals and purposes of ERISA. and therefore, the court adopted it as part of ERISA’s federal common law. View "LeGras v. AETNA Life Ins. Co." on Justia Law

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

This case arose out of a disability benefits dispute between Plaintiff, a retired firefighter for the City of Tracy, California, and the California Association of Professional Firefighters (CAPF), the manager of an employee welfare benefit plan. While a related action was ongoing, Plaintiff initiated a second lawsuit against CAPF, California Administration Insurance Services, Inc. (CAISI), and individual members of the board of directors for both CAPF and CAISI, alleging that Defendants had breached their fiduciary duties under ERISA in the management and administration of the plan. A panel of the Ninth Circuit affirmed in part and reversed in part the district court’s judgment, holding that the district court (1) correctly granted summary judgment for Defendants on a claim that they breached their duty to hold plan assets in trust; (2) erred in granting summary judgment for Defendants on a claim that they breached their fiduciary duties by engaging in unlawful self-dealing; and (3) erred in granting partial summary judgment for Plaintiff where Defendants did not breach their fiduciary duties by failing to distribute a summary annual report. Remanded. View "Barboza v. Cal. Ass’n of Prof’l Firefighters" on Justia Law

Before his retirement, Asa Williams, Sr. participated in various benefit programs (the Xerox Plans), which are subject to the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Asa married Carmen and designated Carmen as his beneficiary. After their divorce, Asa attempted to change his designated beneficiary from his ex-wife to his son (Asa, Jr.). After Asa, Sr.'s death, Carmen claimed to be the beneficiary under the Xerox Plans and Asa, Jr. likewise asserted the same claim. Carmen subsequently moved for summary judgment, asserting that because Asa, Sr. failed to fill out and to return the beneficiary designation forms, he did not properly designate Asa, Jr. as beneficiary in her place. The district court granted the motion. The court concluded that the district court erred in determining that Asa, Sr. was required to abide by the language contained in the forms - but not in the governing plan documents - to change his beneficiary from Carmen to Asa, Jr. Reviewing de novo whether Carmen or Asa, Jr. is entitled to plan benefits, the court concluded that based on the evidence, including Xerox's call log reflecting that Asa, Sr. called Xerox to change his beneficiary designation from Carmen to Asa, Jr., a reasonable trier of fact could determine that Asa, Sr. intended to change his beneficiary to Asa, Jr. and that his phone calls to Xerox constituted substantial compliance with the governing plan documents' requirements for changing his beneficiary designation. Accordingly, the court reversed and remanded. View "Mays-Williams v. Williams" on Justia Law

United is the claims administrator for Plans named as defendants in this suit and all of the Plans are governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Spinedex, as assignee and would-be assignee of Plan beneficiaries, filed suit against United and the Plans seeking payment of denied benefit claims. ACS, as well as individual Plan beneficiaries, Jack Adams and Claude Aragon, joined the suit as plaintiffs. The district court granted summary judgment to defendants. The court reversed, concluding that Spinedex had Article III standing; Spinedex was not assigned the right to bring claims for breach of fiduciary duty; ACS does not have associational standing to bring suit against United; Adams' claim for breach of fiduciary duty is time-barred; Spindex's claims as assignee of beneficiaries under the Martz Agency Plan and the Acoustic Technologies Plan are not time-barred; and the anti-assignment provision of the Discount Tire Plan precluded assignment by Plan beneficiaries to Spinedex. The court vacated or reversed, and remanded for further proceedings, the district court's holdings that Aragon's claim for breach of fiduciary duty was not exhausted, that United is not a proper defendant for benefit claims under the American Express Plan, and that some of the claims assigned to Spinedex were not administratively exhausted. View "Spinedex Physical Therapy v. United Healthcare" on Justia Law

Plaintiffs filed suit alleging that DHL's decision to eliminate plaintiffs' right to transfer their account balances from DHL's defined contribution plan to its defined benefit plan violated the "anti-cutback" rule of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1054(g), which prohibits any amendment of an employee benefits plan that would reduce a participant's "accrued benefit." The court, agreeing with the First Circuit and the district court, concluded that DHL's 2004 plan amendment did not, as a matter of law, violate the anti-cutback rule. The reduction of periodic benefits paid from the Retirement Income Plan that resulted from DHL's elimination of the transfer option did not violate section 1054(g)(1) where the accrued benefits of both the defined contribution and the defined benefit plan remained intact. The court further concluded that the 2004 amendment did not violate the anti-cutback rule as a matter of law where this case fits within the regulatory exception for elimination of an "optional form of benefit," even if the transfer option was such a benefit. Accordingly, the court affirmed the judgment of the district court.View "Andersen v. DHL Retirement Pension Plan" on Justia Law

PSH filed suit against the Wells Fargo & Company Health Plan, governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., and UBH, seeking payment for additional days of inpatient treatment for an employee with severe anorexia nervosa. UBH is a third-party claims administrator of the Plan and UBH refused to pay for more than three weeks of inpatient hospital treatment for the employee. The court concluded that UBH did not follow procedures appropriate to the employee's case; materials outside the administrative record should have been considered by the district court in any review of UBH's benefits denial; and, even conducting an abuse of discretion review uninfluenced by any procedural irregularity or conflict of interest - and considering only the record that UBH had before it when it made its benefits determination - the court held that UBH improperly denied benefits to the employee. The court concluded that UBH improperly denied benefits under the Plan in violation of its fiduciary duty under ERISA. Accordingly, the court reversed the district court's judgment holding otherwise.View "Pacific Shores Hospital v. UBH" on Justia Law

Plaintiff appealed the district court's dismissal of his claims against the Fund and others under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. For over three years, the Fund paid plaintiff monthly pension benefits he had not earned. This case arose from the events that occurred after the Fund discovered the error. The court concluded that it was bound by its own precedent, which correctly identifies surcharge as including only unjust enrichment and losses to the trust estate; the district court properly concluded that plaintiff was not entitled to relief based on estoppel as a matter of law; equitable remedies were not available to plaintiff where the order plaintiff sought necessarily would require violating the terms of the Plan by deeming an ineligible person to be eligible for pension benefits; and the surcharge remedy plaintiff sought would not restore the trust estate, but rather would wrongfully deplete it by paying him benefits he is not eligible to receive under the Plan. Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendants on plaintiff's breach of fiduciary and co-fiduciary duty claims under section 1132(a)(3). The court rejected plaintiff's argument that the Fund failed to comply with ERISA procedural requirements, or that it waived its determination that plaintiff never vested. Therefore, the court affirmed the district court's deference to the Fund's denial of benefits. View "Gabriel v. Alaska Electrical Pension Fund, et al." on Justia Law

Plaintiff appealed the district court's summary judgment in favor of the Plan based on her failure to file the action within the applicable limitation period. The court concluded that plaintiff's right to file an Employee Retirement Income Security Act of 1974, 29 U.S.C. 1001 et seq., action accrued no later than the date her administrative appeal option expired, May 4, 2004, but plaintiff did not file the pending complaint until January 31, 2011. Therefore, the district court correctly concluded that plaintiff's action was barred by the four-year statute of limitation. The court held that the statue of limitations was not revived. Reviving a limitation period when an insurance company reconsiders a claim after the limitation period has run would discourage reconsideration by insurers even when reconsideration might be warranted. The court rejected plaintiff's estoppel and waiver claims. Accordingly, the court affirmed the judgment of the district court. View "Gordon v. Deloitte and Touche" on Justia Law