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Spencer Recovery Centers, Inc. v. Eval Co. of America Medical Plan

Citation: 350 F. App'x 152Docket: Nos. 08-55469, 08-55478, 08-56078, 08-56081

Court: Court of Appeals for the Ninth Circuit; October 28, 2009; Federal Appellate Court

Narrative Opinion Summary

Spencer Recovery Centers, Inc. filed claims for wrongful denial of benefits against Eval Company Medical Plan and Marukyo USA Inc. Health Plan under ERISA. The district court ruled that the Plans had wrongfully denied the claims and ordered them to pay the benefits, along with pre-judgment interest and attorneys’ fees. The appellate court affirmed the district court's judgment, confirming its jurisdiction under 28 U.S.C. 1291. Spencer, as the assignee of the Plans' beneficiaries, requested attorneys’ fees for the appeal, which is typically granted in ERISA cases unless special circumstances exist. The court found no such circumstances in this case and granted Spencer’s request, referring the matter to the Appellate Commissioner to determine the reasonable amount of fees and costs. The district court’s judgment was affirmed, and the disposition is not published or considered precedent except as noted under 9th Cir. R. 36-3.

Legal Issues Addressed

Appellate Jurisdiction Under 28 U.S.C. Section 1291

Application: The appellate court confirmed its jurisdiction to review the district court’s judgment under the statutory framework provided by 28 U.S.C. 1291.

Reasoning: The appellate court affirmed the district court's judgment, confirming its jurisdiction under 28 U.S.C. 1291.

Award of Attorneys’ Fees in ERISA Cases

Application: The court granted Spencer Recovery Centers, Inc.'s request for attorneys’ fees for the appeal, as ERISA cases typically merit such awards unless special circumstances exist, which were not found in this case.

Reasoning: Spencer, as the assignee of the Plans' beneficiaries, requested attorneys’ fees for the appeal, which is typically granted in ERISA cases unless special circumstances exist.

Precedential Value of the Disposition

Application: The court noted that the disposition of the case is not published or considered precedent, except as provided under Ninth Circuit Rule 36-3.

Reasoning: The district court’s judgment was affirmed, and the disposition is not published or considered precedent except as noted under 9th Cir. R. 36-3.

Role of the Appellate Commissioner in Determining Fees

Application: The matter of determining the reasonable amount of attorneys’ fees and costs was referred to the Appellate Commissioner following the court's grant of Spencer's request.

Reasoning: The court found no such circumstances in this case and granted Spencer’s request, referring the matter to the Appellate Commissioner to determine the reasonable amount of fees and costs.

Wrongful Denial of Benefits Under ERISA

Application: The district court found that the Eval Company Medical Plan and Marukyo USA Inc. Health Plan wrongfully denied benefits to Spencer Recovery Centers, Inc., which acted as the assignee of the Plans' beneficiaries.

Reasoning: The district court ruled that the Plans had wrongfully denied the claims and ordered them to pay the benefits, along with pre-judgment interest and attorneys’ fees.