Sawyer

MEMORANDUM *

Thomas Sawyer appeals the district court’s grant of summary judgment to General Life Insurance Company (“General”) in his action for recovery of disability insurance benefits. The district court ruled that Sawyer’s disability insurance plan was covered by the Employee Retirement Income Security Act of 1974 (“ERISA”), and that Sawyer’s state law causes of action were therefore preempted. See 29 U.S.C. § 1144 (a). The court then held that Sawyer’s ERISA claim should be dismissed because his policy denied him benefits if his disability was due to a condition that manifested before the issuance of the policy, and because Sawyer had failed to produce evidence to establish the date of first manifestation of his chronic fatigue syndrome or fibromyalgia.

In reaching this decision, the district court appears to have conducted a proceeding that improperly included features of an Arizona contract law action that are inconsistent with an ERISA action. We therefore vacate its judgment and remand for a proceeding that comports with ERISA.

Because General, in its administrative processing of Sawyer’s claim, did not treat this as a claim for benefits under ERISA, the task of the…