Zagon v. American Airlines, Inc. Long Term Disability Plan

MEMORANDUM

Linda Zagon appeals the district court’s order granting summary judgment to American Airlines, Inc. Long Term Disability Plan (“Plan”). We review de novo, Nolan v. Heald College, 551 F.3d 1148, 1153 (9th Cir.2009), and affirm.

The district court properly declined Za-gon’s invitation to incorporate California’s notice-prejudice rule into ERISA federal common law. First, federal precedent has repeatedly emphasized ERISA’s primary interest in protecting contractually defined benefits, see Black & Decker Disability Plan v. Nord, 538 U.S. 822, 830 , 123 S.Ct. 1965 , 155 L.Ed.2d 1034 (2003), and enforcing a plan as written, see Heimeshoff v. Hartford Life & Accident Ins. Co., — U.S. -, 134 S.Ct. 604, 611-12 , 187 L.Ed.2d 529 (2013). Judicial review focuses on the terms of the plan — terms that employers are given “large leeway” to design, Nord, 538 U.S. at 833 , 123 S.Ct. 1965 and upon which the -parties have come to rely. Here, the Plan explicitly warns beneficiaries that it will not, without exception, consider a claim filed beyond the one-year submission window. No argument can be made, nor was one made here, that this deadline is unreasonable or otherwise conflicts with…