The Ninth Circuit reversed the district court's grant of summary judgment and remanded the case, concluding that the proper standard of review is de novo rather than abuse of discretion because the plan administrator failed to timely decide the appeal within statutory and plan-required timeframes, causing the claim to be deemed denied.
Jebian v. Hewlett-Packard: Court Rules on Disability Benefits Review
Donald Jebian, a Hewlett-Packard employee, was denied disability benefits under his company's income protection plan. When he appealed this decision, the plan administrator failed to respond within the required time limits set by federal law and the plan itself. The lower court initially ruled in favor of Hewlett-Packard, using a lenient standard that gave the company significant deference in its decision-making.
The Ninth Circuit Court of Appeals reversed this decision and sent the case back to the lower court. The appeals court ruled that because the plan administrator missed the legal deadlines for responding to Jebian's appeal, the denial should be treated as automatic. More importantly, the court determined that when reviewing the case again, judges must use a stricter "de novo" standard, meaning they can fully examine the evidence themselves rather than simply deferring to the employer's judgment.
This ruling matters for workers because it holds employers accountable for following proper procedures when handling disability benefit appeals. When companies fail to meet legal deadlines, workers get the benefit of having their cases reviewed more thoroughly by courts, improving their chances of a fair outcome.
This summary was generated to explain the ruling in plain English and is not legal advice.
Other orders and opinions in Donald Jebian v. Hewlett-Packard Company Employee Benefits Organization Income Protection Plan Erisa Plan from the same court.
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