E.J. v. Montana Contractors' Ass'n Healthcare Trust

MEMORANDUM

Appellant E.J. filed a complaint in district court under 29 U.S.C. § 1132 (a)(1)(B) of the Employee Retirement Security Act of 1974 (“ERISA”) after Appellee Montana Contractors’ Association Healthcare Trust (“MCAHT”) denied coverage of E.J.’s medical expenses. MCAHT denied benefits on the basis of E.J.’s refusal 1) to provide a copy of a malpractice settlement, 2) to provide a copy of a state court order directing the use of funds from the settlement, including the dollar amount of the settlement funds allocated to E.J., 3) to provide a copy of a special needs trust (“SNT”), and 4) to sign a third-party reimbursement agreement (“TPRA”). Concluding that E.J. was required to provide this information under the terms of the health plan, the district court granted MCAHT’s motion for summary judgment. While we agree with the district court that MCAHT did not abuse its discretion in denying benefits, we conclude that E.J.’s subsequent disclosure of information and willingness to seek judicial authorization to provide any necessary documentation makes remand the appropriate remedy in this case. We therefore vacate the order granting summary judgment, with instructions to…