Prichard v. Metro. Life Ins. Co., No. 12-17355 (9th Cir. 2015)
Annotate this CaseAfter 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.
Court Description: ERISA. The panel vacated the district court’s judgment in an action challenging an ERISA plan administrator’s decision to deny the plaintiff long-term disability benefits. The panel held that the district court erred in reviewing the benefits denial for an abuse of discretion, rather than de novo, when a Summary Plan Description conferred discretionary authority upon the plan administrator but a governing plan document in the form of an insurance certificate did not. The panel remanded for the district court to review the denial of benefits de novo.
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