Powell

Powell v. General American Life Insurance

Good Law
1990 Cal. App. LEXIS 660·221 Cal. App. 3d 817·271 Cal. Rptr. 16
Court of Appeal of CaliforniaJune 25, 1990No. D009844California2,305 words

Opinion

Lead Opinion

Work, J.

*819 Opinion

Stanley Powell appeals a judgment in favor of General American Life Insurance Company (General American), denying his claim for medical insurance benefits under his employer’s benefit plan for his dependent daughter. The trial court ruled in favor of General American based on its belief equitable estoppel could not be applied to create insurance coverage under a plan governed by the Employee Retirement Income Security Act (ERISA) (see 29 U.S.C. § 1001 et seq.). We hold those judicial decisions precluding the use of estoppel to create coverage contrary to the terms of an employee benefit plan where claimants are ineligible under the substantive provisions of the plan, do not preclude the use of estoppel to excuse a prerequisite which is only procedural, so as to allow coverage of an otherwise eligible claimant. The judgment is reversed.

Facts

The case was submitted to the trial court on stipulated facts, which we summarize as follows. General American issued a group health insurance plan to Four Winds Van Lines, Inc., Powell’s employer. General American contracted with Trimpe Gilbert Corporation to solicit applications for and to administer its group insurance…

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