Articles Posted in US Court of Appeals for the Ninth Circuit

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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

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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

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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