Summary
The United States District Court for the District of Kansas overruled Blue Cross and Blue Shield of Kansas, Inc.'s motion for judgment on the pleadings in an ERISA benefits dispute involving an alleged assignment of benefits to a healthcare provider. The court held that the anti-assignment language presented in the limited plan excerpt was ambiguous as to whether it barred assignment of the right to sue for benefits. The court also ordered the plaintiff to file a reply to the defendant's answer.
Holdings
- The anti-assignment provision was ambiguous as to whether it prohibited assignment of all plan rights, only appeal rights, or the right to sue for benefits; therefore, the court declined to enforce it on a motion for judgment on the pleadings.
- Judgment on the pleadings was inappropriate because the court could not determine the meaning and scope of the anti-assignment provision as a matter of law from the incomplete and conflicting record.
Questions Presented
- Whether BCBS was entitled to judgment on the pleadings because the plan's anti-assignment provision unambiguously barred plaintiff, as assignee, from suing for ERISA benefits.
- Whether the limited plan provision and conflicting evidentiary submissions permitted the court to determine the enforceability and scope of the anti-assignment provision as a matter of law on a Rule 12(c) motion.
Disposition
other
Cases Cited (18)
- Sanders v. Mountain Am. Fed. Credit Union, 689 F.3d 1138, 1141 (10th Cir. 2012)(followed)
- Jenkins v. Cnty. of Washington, 126 F. Supp. 3d 255, 274 (N.D.N.Y. 2015)(followed)
- Atl. Richfield Co. v. Farm Credit Bank, 226 F.3d 1138, 1160 (10th Cir. 2000)(followed)
- Mock v. T.G. & Y. Stores Co., 971 F.2d 522, 528 (10th Cir. 1992)(followed)
- Ashcroft v. Iqbal, 556 U.S. 662, 678-80 (2009)(followed)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555-57 (2007)(followed)
- Conley v. Gibson, 355 U.S. 41, 45-46 (1957)(followed)
- GFF Corp. v. Associated Wholesale Grocers, Inc., 130 F.3d 1381, 1384 (10th Cir. 1997)(followed)
- Scheuer v. Rhodes, 416 U.S. 232, 236 (1974)(followed)
- Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991)(followed)
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Cited In (0)
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Court Document
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