Argued and Submitted, San Francisco, California
January 15, 2015
Appeal from the United States District Court for the Northern District of California. D.C. No. 4:10-cv-03313-SBA. Saundra B. Armstrong, District Judge, Presiding.
VACATED AND REMANDED.
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.
Scott Kalkin (argued), Roboostoff & Kalkin, San Francisco, California, for Plaintiff-Appellant.
Rebecca Ann Hull (argued), Sedgwick LLP, San Francisco, California, for Defendants-Appellees.
Before: J. Clifford Wallace, Milan D. Smith, Jr., and Michelle T. Friedland, Circuit Judges.
WALLACE, Senior Circuit Judge:
Matthew Prichard appeals from the district court's judgment affirming Metropolitan Life Insurance Company's (MetLife) decision to deny him long-term disability benefits under the long term disability plan of his employer, IBM. We have jurisdiction over this appeal pursuant to 28 U.S.C. § 1291. Prichard argues that the district court erred in reviewing MetLife's decision for an abuse of discretion, rather than de novo. He argues in the alternative that even if the district court was correct in using the abuse of discretion standard, MetLife abused its discretion here. We hold that the district court should have reviewed ...