Andi Cox v. WSP USA Inc. Group Insurance Plan, Inc.

Summary

The United States District Court for the Northern District of California ruled on motions in Andi Cox’s ERISA action against the WSP USA Inc. Group Insurance Plan concerning coverage for facial feminization surgery. The court granted the motion to seal, granted in part and denied in part requests for judicial notice and incorporation by reference, and held that the prior settlement did not bar Cox’s current claims. The court dismissed the denial-of-benefits claim without leave to amend because the plan documents expressly excluded the requested procedures as cosmetic and not medically necessary.

Holdings

1. The court may incorporate documents by reference when the complaint refers to them, they are central to the claims, and their authenticity is not genuinely disputed; it may judicially notice the existence of a public court docket but not disputed facts contained in public records. The court incorporated the Benefit Booklet, Policy Bulletin, and Settlement Agreement, took judicial notice of the prior case docket, and declined to incorporate or notice the Master Services Agreement, Wrap Plan, and Summary Plan Description.
2. The settlement agreement resolving claims related to facial hair removal did not bar Cox's current claims concerning facial feminization surgery.
3. Cox failed to state a claim for denial of benefits under ERISA because the plan expressly excluded the facial feminization procedure she sought as cosmetic and not medically necessary under the incorporated Policy Bulletin.
4. Leave to amend the denial-of-benefits claim was denied because amendment would be futile in light of the plan's plain and unambiguous exclusion of the requested procedure.

Questions Presented

1. Whether the court could incorporate the Benefit Booklet, Policy Bulletin, and Settlement Agreement by reference and take judicial notice of the prior case docket while deciding the Rule 12(b)(6) motion.
2. Whether the settlement agreement resolving Cox's prior facial hair-removal claims released her current claims concerning facial feminization surgery.
3. Whether Cox plausibly stated an ERISA claim for denial of benefits when the plan documents expressly excluded the facial feminization procedure as cosmetic and not medically necessary.
4. Whether Cox should be granted leave to amend the denial-of-benefits claim.

Disposition

other