Brad Harper and Mary Deborah Harper, Husband and Wife v. American Chambers Life Insurance Company, a Group Health Insurer; United Chambers Administrators, Inc.; American Employers Association

Summary

The Ninth Circuit held that the record was insufficient to determine whether a partnership’s health insurance policy constituted an ERISA plan. The court reversed the dismissal of the Harpers’ state-law claims and remanded for factual findings regarding the policy’s ERISA status. It further held that, if the policy was an ERISA plan, the Harpers could potentially sue as ERISA beneficiaries to recover benefits.

Holdings

1. The existence of an ERISA plan is a question of fact requiring consideration of all surrounding facts and circumstances from the perspective of a reasonable person. The limited record did not establish as a matter of law either that the policy was or was not an ERISA plan, and the district court erred by deciding the issue as a matter of law.
2. If the policy is an ERISA plan, the Harpers are eligible to bring ERISA claims as beneficiaries under ERISA's civil-enforcement provision because they are persons designated by the terms of the plan as persons who are or may become entitled to benefits.
3. Even if the policy is an ERISA plan, dismissal is not necessarily proper because the Harpers may pursue ERISA claims as beneficiaries; if the policy is not an ERISA plan, they may proceed with their state-law claims.

Questions Presented

1. Whether the partnership's medical insurance policy was an employee welfare benefit plan governed by ERISA.
2. Whether the Harpers could bring claims under ERISA as beneficiaries if the policy was an ERISA plan.
3. Whether the district court erred by dismissing the Harpers' state-law claims without determining through factual findings whether the policy was an ERISA plan.

Disposition

reversed_and_remanded