No specific laws identified for this ruling.
Defendant Cleveland Clinic Employee Health Plan prevailed on standing grounds. The court found that plaintiff Angel Jet Services, LLC lacked standing to pursue ERISA claims because the only assignment of benefits in the record was from Athena Springer (the spouse) to AJS, executed before Athena had vested rights in the Cleveland Clinic plan, and that assignment referenced only her prior Regence Blue Cross Blue Shield of Utah policy, not the Cleveland Clinic plan.
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