Eric P. v. Directors Guild of America

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 6 ERIC P., Case No. 19-cv-00361-WHO

Plaintiff,

ORDER ON STANDARD OF REVIEW

v. 9 Re: Dkt. No. 37 DIRECTORS GUILD OF AMERICA, et al., Defendants.

Plaintiff seeks review of the Directors Guild of America-Producer Health Plan’s decision denying his claim of coverage for residential mental health treatment for his daughter. The question at issue here is what standard of review – de novo or abuse of discretion – applies to my review of the Plan’s denial. Plaintiff argues de novo review is appropriate, despite the discretion provided to the Trustees of the Plan and through them to the Benefits Committee under the terms of the Plan, because: (1) because the Plan documents granted deference to so many entities involved in the claim-decision process, that grant is “anything but clear and unambiguous,” as required in the Ninth Circuit; (2) the Trust documents do not provide deferential decision-making authority over claims to the Benefits Committee that made the final…