Northern District of California Vacates Prior Remedies and Enters Sweeping Injunctive Relief Against United Behavioral Health for Fiduciary Breaches in Guideline Development

In Wit v. United Behavioral Health, No. 14-CV-02346-JCS, 2026 WL 290352 (N.D. Cal. Feb. 3, 2026), the Northern District of California issued an amended remedies order in this long-running litigation, vacating its prior remedies order and entering broad declaratory and injunctive relief against United Behavioral Health (“UBH”) for systemic breaches of fiduciary duty under the Employee Retirement Income Security Act of 1974 (“ERISA”). The amended order follows years of litigation over UBH’s use of proprietary behavioral health guidelines to administer mental health and substance use disorder benefits under ERISA-governed plans.

Following the Ninth Circuit’s most recent rulings and the district court’s earlier breach-of-fiduciary-duty findings, the court held that UBH acted as an ERISA fiduciary when it developed, revised, and adopted its internal behavioral health Guidelines used to interpret plan medical-necessity requirements tied to generally accepted standards of care (“GASC”). Although the plans at issue required covered services to be consistent with GASC, the court emphasized that UBH’s proprietary Guidelines were not themselves plan terms. Instead, the Guidelines functioned as interpretive tools that materially shaped coverage determinations. As a result, UBH was required to develop and apply those Guidelines solely in the interests of plan participants and beneficiaries and with the care, skill, prudence, and diligence required of ERISA fiduciaries.

The court found that, throughout the class period, UBH’s guideline-development process was tainted by financial self-interest and a lack of due care. The evidence showed that UBH’s internal processes prioritized cost containment and utilization management goals over alignment with prevailing clinical standards. The court concluded that this misconduct was willful and systematic, affecting class members on a classwide basis rather than through isolated or discretionary errors. As a result, the challenged Guidelines were deemed “irreparably tainted” and incapable of being cured through retrospective application.

Substantively, the court found that the Guidelines were significantly and pervasively more restrictive than generally accepted standards of care. They were structured to emphasize acute crisis stabilization rather than the effective treatment of underlying mental health and substance use disorders. The Guidelines failed to account adequately for co-occurring conditions, discouraged treatment at higher levels of care even when clinically appropriate, and did not err on the side of caution when placement decisions were ambiguous. The court also found that the Guidelines improperly limited coverage for services intended to maintain functioning or prevent deterioration, imposed rigid and mandatory prerequisites inconsistent with individualized, multidimensional clinical assessments, and failed to address the unique needs of children and adolescents. In several respects, the Guidelines substituted bright-line exclusions and utilization thresholds for professional clinical judgment.

In addition to violations of the Employee Retirement Income Security Act, the court concluded that UBH violated multiple state laws requiring the use of state-mandated criteria or the American Society of Addiction Medicine Criteria (“ASAM Criteria”) for substance-use-disorder treatment. The court found that UBH knowingly misrepresented the consistency of its Guidelines with the ASAM Criteria to regulators and continued to apply its internal Guidelines in jurisdictions that required adherence to specific statutory or regulatory standards. These failures, the court held, deprived affected plan participants of their right under ERISA to have plan terms administered in accordance with governing state law.

As relief, the court permanently enjoined UBH from using the challenged Guidelines to implement generally accepted standards of care requirements in ERISA–governed plans. The court further ordered that, for a period of five years, any criteria adopted by UBH to implement GASC requirements must accurately reflect generally accepted standards of care and comply with applicable state law. The court retained jurisdiction for the same period to ensure compliance and oversee implementation of the injunctive relief.