Williby v. Aetna Life Insurance Co., No. 15-56394 (9th Cir. 2017)Annotate this Case
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.