Patterson

Martin Patterson appeals the district court’s judgment rejecting his claim under the Employee Retirement Income Security Act, 29 U.S.C. § 1132 (a)(1) against an employee benefits plan and its insurance company.

Patterson worked for Hughes Aircraft Company (Hughes) and was covered by the Hughes Salaried Employees’ Income Insurance Plan. Benefits under the Plan were paid by Centennial Insurance Company. Patterson filed a claim for disability benefits due to headaches. Centennial found him totally disabled and began paying benefits. Centennial terminated the benefits two years later on the ground Patterson’s disability was mental rather than physical, and that he had exhausted the policy’s two-year limitation on benefits resulting from “mental, nervous or emotional disorders of any type.” At Patterson’s request, Centennial reviewed the termination of benefits twice, each time concluding his disability was mental and therefore subject to the limitation. Patterson sued Centennial in state court; Centennial removed the case to the court below.

After a one-day trial, the district court held (1) the term “mental disorder” in the Plan was not ambiguous, (2) Centennial did not abuse its…