Jack Leeson v. Transamerica Disability Income

Plaintiff Jack Leeson (“Leeson”), a former employee of Defendant Transamerica Corporation (“Transamerica”), filed this action under the Employee Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1101 , et seq., to challenge the termination of his long-term disability benefits. The district court, applying an abuse of discretion standard of review, upheld the Transamerica Corporation Disability Income Plan’s decision to terminate his benefits. Leeson appealed. In a prior disposition, we reversed the district court’s grant of summary judgment to Transamerica and remanded with instructions to the district court to apply a de novo standard of review in determining whether Transamerica properly terminated Leeson’s benefits. Leeson v. Transamerica Disability Income Plan, 279 Fed.Appx. 563 (9th Cir. 2008).

On remand, Transamerica filed a motion to dismiss Leeson’s action for lack of subject matter jurisdiction on the ground that Leeson did not have statutory standing as a plan participant to file suit under ERISA. Leeson, on the other hand, argued that he was a plan participant because he was employed at Transamerica at the time he applied for benefits. Leeson also stressed…