Narrative Opinion Summary
The appellate court reviewed a summary judgment from the district court favoring Stryker Corporation and its Group Life Insurance Plan. Lydia Winterstein, the appellant, disputed the denial of supplemental life insurance benefits by Continental Assurance Company (CNA) following the death of her mother, a Plan member. The Employee Retirement Income Security Act (ERISA) governed the Plan, designating Stryker Corporation as the administrator with discretionary authority. However, CNA, which made the benefits denial, lacked such authority per the Plan's terms, warranting a de novo review of its decision. The court found no explicit delegation of discretionary authority to CNA, aligning with precedents requiring clear Plan provisions for such delegation. Furthermore, ambiguities regarding the status of rehired employees were resolved using the doctrines of contra proferentem and reasonable expectations, favoring the interpretation that entitled Blanca Winterstein to benefits as a newly rehired employee. Consequently, the court reversed the district court's judgment and remanded the case, ordering entitlement to life insurance benefits for Lydia Winterstein. This decision is subject to citation limitations under Ninth Circuit Rule 36-3.
Legal Issues Addressed
Delegation of Authority in ERISA Planssubscribe to see similar legal issues
Application: The Plan did not explicitly provide for the delegation of discretionary authority to CNA, which affected the standard of review applied to CNA's denial of benefits.
Reasoning: The Plan does not contain a provision explicitly allowing such delegation, unlike other plans cited in case law.
Doctrine of Contra Proferentem in Plan Ambiguitiessubscribe to see similar legal issues
Application: The court applied contra proferentem to resolve ambiguities in the Plan concerning the status of rehired employees, favoring Blanca Winterstein's interpretation.
Reasoning: When faced with ambiguity in the Plan’s terms regarding rehired employees, the court applies the doctrines of contra proferentem and reasonable expectations, constraining the interpretation in favor of Blanca Winterstein.
Entitlement to Insurance Benefits under ERISA Plansubscribe to see similar legal issues
Application: Lydia Winterstein was entitled to the life insurance benefits due to her mother’s proper enrollment under the Plan terms, as interpreted by the court.
Reasoning: Consequently, the court concludes that Lydia Winterstein is entitled to both basic and supplemental life insurance benefits for which her mother enrolled and paid.
ERISA Plan Interpretation and Discretionary Authoritysubscribe to see similar legal issues
Application: The appellate court determined that the denial of benefits by CNA must be reviewed de novo because CNA lacked discretionary authority to interpret the Plan terms.
Reasoning: The court cites precedent indicating that CNA's decision must be reviewed de novo unless the Corporation had properly delegated discretionary authority to CNA.