Articles Posted in US Court of Appeals for the Ninth Circuit

by
The Ninth Circuit reversed the district court's judgment in favor of MetLife in an action filed by plaintiff to seek life insurance benefits under a benefits plan governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The panel held that MetLife waived the evidence of insurability requirement because it did not ask plaintiff for a statement of health, even as it accepted her premiums for $250,000 in coverage. In this case, MetLife's purported ignorance of the facts did not negate its obligation to pay the entire $250,000 because, under agency law, the policyholder-employer's knowledge and conduct may be attributed to MetLife. View "Salyers v. Metropolitan Life Insurance Co." on Justia Law

by
The Ninth Circuit reversed the district court's grant of summary judgment to defendants in an action under the Employee Retirement Income Security Act (ERISA). Plaintiff alleged that defendants failed to adequately disclose that the lifetime benefit maximum applied to the plan at issue. The panel held that ERISA, as amended by the Affordable Care Act, does not ban lifetime benefit maximums for certain retiree-only plans; defendants violated ERISA's statutory and regulatory disclosure requirements by providing a faulty summary of material modifications describing changes to the lifetime benefit maximum in September 2010; and genuine disputes of material fact preclude summary judgment on the breach of fiduciary duty claims. View "King v. Blue Cross and Blue Shield" on Justia Law

by
After Aetna determined that plaintiff was not disabled and terminated her benefits, she filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The district court applied de novo review and held that Aetna improperly denied plaintiff's claim. The Ninth Circuit vacated the district court's judgment, holding that the district court should have reviewed the denial only for abuse of discretion. The panel held that the plan contained a discretionary clause and thus called for abuse of discretion review; Aetna provided no sound reason to depart from the text of section 22 of the California Insurance Code, which brought within the scope of Cal. Ins. Code 10110.6 Boeing's self-funded STD plan; ERISA preempted application of section 10110.6 to Boeing's self-funded plan; and remand was necessary to permit the district court to properly apply the abuse of discretion standard. View "Williby v. Aetna Life Insurance Co." on Justia Law

by
The Ninth Circuit vacated the district court's grant of summary judgment in favor of plaintiffs in an Employee Retirement Income Security Act (ERISA) action. The panel held that the plan comprised of two documents: the Trust Agreement and the Summary Plan Description (SPD). The Supreme Court's decision in CIGNA Corp. v. Amara, 563 U.S. 421 (2011), was not to the contrary. An SPD may constitute a formal plan document, consistent with Amara, so long as the SPD neither adds to nor contradicts the terms of existing plan documents. In this case, the SPD was a part of the plan itself, and there was no conflict between the SPD and the Trust Agreement. Therefore, Amara did not prohibit this type of arrangement, and the district court erred in concluding that the SPD was not part of the plan. The panel remanded for further proceedings. View "Mull v. Motion Picture Industry Health Plan" on Justia Law

by
Plaintiff filed a putative class action alleging that the Trustees breached the Pension Plan's terms, violated the Employee Retirement Income Security Act's (ERISA) sections 204 and 305, and breached their fiduciary duties by withholding $1.00 per hour from his employer contributions without providing an accrued benefit. The Ninth Circuit held that only amendment 14 was fully litigated; the district court correctly interpreted the interaction between Amendment 15, Article 5 of the Pension Plan, and the Reciprocal Agreement; ERISA section 305(e) does not apply before critical status certification; and because the panel held that the parties did not fully litigate withholdings under Amendment 24, it need not address whether the district court erred by failing to make specific findings about the alternative schedules in the Rehabilitation Plan. Accordingly, the panel affirmed in part, reversed in part, and remanded for further proceedings on the withholdings under Amendment 24. The panel vacated the award of attorneys' fees. View "Lehman v. Nelson" on Justia Law