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Home > Blog > Ninth Circuit Finds Claim for Occupational Disability Pension Benefits Constructively Denied for Plan’s Failure to Comply with ERISA’s Time Limits

Ninth Circuit Finds Claim for Occupational Disability Pension Benefits Constructively Denied for Plan’s Failure to Comply with ERISA’s Time Limits

Hoffman v. Screen Actors Guild-Producers Pension Plan, No. 20-55534, __F.App’x__, 2021 WL 1041693 (9th Cir. Mar. 18, 2021) involves a former stuntwoman’s claims for Disability Pension and Occupational Disability Pension benefits under the Defendant Screen Actors Guild-Producers Pension Plan. The lawsuit has a “tortured history” and this is the case’s third time at the Ninth Circuit. The initial lawsuit challenged the Plan’s decision finding that there was no “occupational nexus” between her disability from severe major depression and her stunt work which is required for lifetime health coverage benefits. When she filed that lawsuit, she was receiving monthly disability pension benefits. The district court ruled for the Plans and the Ninth Circuit reversed, finding that the Plans denied her a full and fair review of her claim for entitlement under the Occupational Disability Plan. The district court remanded the claim to the Plans, and on remand, the Plan not only confirmed its original denial, but it retroactively denied Hoffman’s disability pension benefits and claimed she owed them money. The district court ruled for the Plan and the Ninth Circuit reversed again, finding that Hoffman was denied a full and fair review. On remand, the district court found that the Pension Plan abused its discretion in terminating Hoffman’s disability benefits and remanded the matter to the Pension Plan. The district court then entered the parties’ stipulated judgment and awarded Hoffman attorneys’ fees for the second lawsuit. Hoffman then sought to reopen the first lawsuit so she could pursue her claim for lifetime medical benefits, which was not resolved earlier. But the district court only allowed Hoffman to pursue attorneys’ fees for work related to the first lawsuit but would not reopen the case to adjudicate her entitlement to future health benefits.

The essence of this dispute is whether the district court erred when it denied Hoffman’s request to reopen the case to adjudicate her entitlement to future health benefits under the Occupational Disability Pension plan. The court determined that it has jurisdiction to review the Order based on a practical construction of 28 U.S.C. § 1291’s final decision rule. The Plan represented that it had no intention of acting further on this matter. Absent the court’s review, Hoffman would be left “effectively out of court.”

The court found that the district court erred by not granting the Order in full. The Plans constructively denied Hoffman’s claim in whole following the district courts first administrative remand in 2014 when it did not comply with the regulatory time limits for deciding disability benefits claims. 29 C.F.R. § 2560.503-1(i)(3)(i). Because the claim was denied, she was entitled to district court review. The Ninth Circuit directed the district court to reopen the first lawsuit and decide de novo whether Hoffman is entitled to continuing health benefits.

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