Banacky v. Prudential Insurance Co. of North America
Docket: No. 03-57008; D.C. No. CV-03-00446-CJC
Court: Court of Appeals for the Ninth Circuit; March 17, 2005; Federal Appellate Court
Prudential denied Judith Banacky’s claims for benefits under an ERISA disability plan, leading to a review of the case due to the plan administrator lacking discretionary authority. The district court upheld Prudential’s termination of benefits, determining the decision should be reviewed de novo. Banacky had received rehabilitation benefits from August 1995 to July 1997, after which benefits were terminated as a more restrictive standard requiring that the policyholder be unable to perform any job for which they are reasonably qualified came into effect. The court found that Banacky was not totally disabled from performing any full-time job as of August 1997, and thus, the termination of benefits was affirmed. Banacky continued part-time work until April 1998 and submitted a second claim for long-term disability benefits in December 1999, retroactive to April 1998. This claim was denied on the basis that she had not returned to full-time employment since January 1995, and the district court agreed with Prudential, stating she was ineligible for coverage. The court emphasized that ERISA plans must be interpreted according to their clear language, which in this case stipulated that coverage is only available for full-time employees. Banacky’s status as a part-time employee since 1995 meant she was no longer covered under the plan, and her second claim was properly denied. The appellate court affirmed the district court's decision, stating that Banacky’s coverage ended in August 1997 due to her failure to maintain full-time work status. The ruling concludes that the plan’s terms do not allow for coverage to extend to individuals who are not currently covered, and the provision for treating separate periods of total disability as one does not apply in her case. The decision is affirmed and not suitable for publication or citation in the circuit’s courts.