Mehen v. Delta Airlines, Inc.

Summary

The Ninth Circuit affirmed the district court’s use of abuse-of-discretion review in an ERISA action challenging the termination of disability benefits. The court held that the plan granted discretionary authority to the administrator, and concluded that the termination of benefits and denial of extended COBRA coverage were not abuses of discretion.

Holdings

1. When an ERISA plan grants the administrator discretionary authority to determine eligibility for benefits or construe plan terms, the court reviews the administrator's decision for abuse of discretion rather than de novo.
2. A conflict of interest or procedural irregularity does not ordinarily require de novo review when the plan grants discretionary authority; instead, those circumstances are weighed in determining whether the administrator abused its discretion.
3. The plan administrator did not abuse its discretion by terminating Mehen's disability benefits because the decision was not arbitrary and capricious and had a reasonable basis in the record.
4. The plan did not abuse its discretion by denying Mehen's request for an extension of COBRA benefits because the qualifying event did not occur within the initial 18-month COBRA period and Mehen failed to provide notice within the plan's required 60-day period.

Questions Presented

1. Whether the district court applied the correct standard of review to the termination of Mehen's ERISA disability benefits.
2. Whether an administrator's alleged conflict of interest or procedural violations required de novo review.
3. Whether the plan administrator abused its discretion by terminating Mehen's disability benefits.
4. Whether the plan abused its discretion by denying Mehen's request for an extension of COBRA benefits.

Disposition

affirmed