Mellor v. Wasatch Crest Mutual Insurance Co.

Summary

The Supreme Court of Utah held that a minor remained covered under an employer-sponsored health plan despite becoming eligible for Medicaid. The court found ambiguity in the plan's exclusions and concluded that federal and state law prohibited terminating coverage based on Medicaid eligibility; it affirmed the mother's standing to proceed on her son's behalf and reversed the ruling denying coverage.

Holdings

1. A minor beneficiary may pursue recovery of benefits under ERISA, and the minor's mother has standing to bring the action on his behalf under Utah Rule of Civil Procedure 17.
2. The plan's exclusion for expenses covered by government programs and its exclusion for services covered by Medicare or other government programs, except Medicaid, created inconsistent meanings when read together and were therefore ambiguous.
3. Hayden's coverage under the Wasatch Crest plan did not terminate as a matter of law when he became eligible for or received Medicaid coverage.

Questions Presented

1. Whether Chris Ann Williams Mellor had standing to pursue a claim for benefits on behalf of her minor son.
2. Whether Hayden's coverage under the Wasatch Crest plan terminated when he became eligible for or received Medicaid coverage.
3. Whether the plan's exclusions for expenses covered by government programs and services covered by Medicare or other government programs, except Medicaid, were ambiguous or otherwise unenforceable under federal and Utah law.

Disposition

reversed_and_remanded