Rose Gordon, as Administratrix of the Estate of Angelina Miller v. Ilwu-Pma Benefit Funds

This is an appeal by the Trustees of the International Longshoremen’s and Ware-housemen’s Union Pacific Maritime Association Welfare Plan (“the Plan”) from a judgment requiring the Plan to pay extended death benefits to the estate of Angelina Miller. The district court held that $8000 was due Mrs. Miller at the time of her death as a benefit stemming from the prior death of her husband, Ira G. Miller.

The trustees had denied the estate’s claim on the grounds that Mrs. Miller failed to complete the documentation necessary to establish her eligibility before her death, and that payment to the estate of a dependent was contrary to the intended purpose of the Plan (to provide benefits to living dependents). The district court found that the trustees acted arbitrarily and capriciously in denying payment to the estate because they failed to disclose specifically to participants that extended benefits would be denied if a beneficiary did not personally complete the necessary forms.

On appeal, the trustees contend that the district court erroneously applied principles developed by state courts in interpreting commercial insurance contracts. We agree, and, in accordance with our decision…