Emma Connor v. Meta Platforms, Inc. Health and Welfare Benefit Plan

Summary

The United States District Court for the District of Oregon denied Meta Platforms, Inc. Health and Welfare Benefit Plan’s motion to dismiss an ERISA action under Rules 12(b)(1) and 12(b)(6). The court held that the plaintiff plausibly alleged Article III standing and identified a Plan provision that could cover the requested gender-affirming procedures, including clavicle shortening, scapular spine shaving, and rib remodeling. The court found that ambiguities in the Plan and the applicability of related Aetna guidelines required further proceedings.

Holdings

1. A current participant who alleges that the Plan denied benefits allegedly owed under a specific Plan provision sufficiently alleges an injury in fact for Article III standing purposes.
2. The complaint plausibly stated a claim because the Plan's coverage of 'reconstructive and complementary procedures for body and face feminization and masculinization' could encompass Plaintiff's requested procedures.
3. The complaint did not assert an independent claim based on procedural mishandling; allegations concerning the Plan administrator's procedures were treated as allegations supporting exhaustion of administrative remedies.

Questions Presented

1. Whether Plaintiff plausibly alleged an injury in fact sufficient to establish Article III standing for an ERISA claim seeking benefits under the Plan.
2. Whether Plaintiff identified a specific Plan provision that plausibly could entitle her to coverage for the requested gender-affirming procedures.
3. Whether the complaint should be dismissed under Rule 12(b)(1) or Rule 12(b)(6).

Disposition

other