In an employee benefits case brought in federal court under the Employee Retirement Income Security Act (ERISA) against our client, a national retailer, and its group health insurance plan for denial of an expensive surgery as not medically necessary, the court granted judgment in favor of our clients at the time of trial.
The court ordered trial briefs from both parties in advance of trial, which plaintiff provided. Payne & Fears went a step further and in conjunction with our trial brief, moved for judgment on partial findings pursuant to Federal Rule of Civil Procedure 52(c) based on an undisputed administrative record. Under Rule 52(c), a federal court has discretion to enter judgment when a party has been fully heard on an issue, but can decline to render judgment until the close of evidence.
Having received our motion and plaintiff’s opposition, and having previously ruled in the plan’s favor that the abuse of discretion standard of review applied, the court took the matter under submission, took the trial date off calendar, and entered judgment in defendants’ favor. The court thus upheld the decision of the plan administrator to deny coverage for the surgery without conducting a trial.
Eric C. Sohlgren defended the case on behalf of the plan and prepared the motion for judgment, with Andrew K. Haeffele assisting.