O. et al v. United Behavioral Health et al
Filing
106
MEMORANDUM DECISION AND ORDER granting 92 Motion to Reopen Case. The Clerk is directed to reopen this case. The parties are directed to file their cross motions for summary judgment by March 15, 2024. Signed by Judge Ted Stewart on 1/16/2024. (mh)
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF UTAH
GRAHAM O. and LINDA O., individually
and as guardian of J.O., a minor,
MEMORANDUM DECISION AND
ORDER GRANTING PLAINTIFFS’
MOTION TO REOPEN CASE
Plaintiffs,
v.
UNITED BEHAVIORAL HEALTH and JP
MORGAN GROUP HEALTH PLAN,
Case No. 1:18-CV-31-TS
District Judge Ted Stewart
Defendants.
This matter is before the Court on Plaintiffs’ Motion to Reopen Case. For the reasons
discussed below, the Court grants the Motion.
I. BACKGOUND
Plaintiffs brought this action under the Employee Retirement Income Security Act of
1974 (“ERISA”) based on Defendants’ denial of benefits for mental health care J.O. received at
two treatment facilities. On cross motions for summary judgment, this Court per the Honorable
Bruce S. Jenkins, determined that Defendants had acted arbitrarily and capriciously in denying
benefits and remanded the case to United Behavioral Health (“United”) to more adequately
explain its decision.
On remand, United again denied Plaintiffs’ request for benefits. Plaintiffs now seek to
reopen this case arguing that United’s denials on remand were still arbitrary and capricious and
suffered from other deficiencies. Defendants oppose, asserting that the denials were supported by
substantial evidence.
1
II. DISCUSSION
Generally, when an ERISA case is remanded to the plan administrator for further
proceedings, the decision on remand is reviewable by the District Court upon motion by either
party. 1 Given this, it is appropriate to reopen this case to evaluate United’s most recent denials.
While the Court understands United’s insistence that it complied with the Court’s remand order
and that its denials were well supported, this Motion is ill-suited to resolve such arguments.
Instead, the Court will direct the parties to file cross motions for summary judgment, as is
customary in ERISA cases. 2
1
Stevens v. Santander Holdings, USA Inc., 799 F.3d 290, 299 (3d Cir. 2015) (noting that
either party could file “a motion to reopen the case in the District Court after the remand to the
plan administrator”); Young v. Prudential Ins. Co. of Am., 671 F.3d 1214, 1216 (11th Cir. 2012)
(quoting Petralia v. AT&T Glob. Info. Sols. Co., 114 F.3d 352, 354 (1st Cir. 1997)) (adopting
position that “a party seeking judicial review in the district court [after remand] may do so by a
timely motion filed in the same civil action”); Graham v. Hartford Life & Accident Ins. Co., 501
F.3d 1153, 1159 (10th Cir. 2007) (stating that “Hartford has conceded that if its benefits
determination on remand is unfavorable to [Graham], she may simply move to reopen the case,
or file an amended complaint to address any dissatisfaction with Hartford’s decision on remand”)
(alteration in original) (quotation marks omitted); Bowers v. Sheet Metal Workers’ Nat’l Pension
Fund, 365 F.3d 535, 537 (6th Cir. 2004) (finding that a remand to the plan administrator
“permit[ted] either party to challenge the eligibility determination that the plan administrator
renders on remand”); Petralia, 114 F.3d at 354 (“Ordinarily implicit in a federal district court’s
order of remand to a plan fiduciary is an understanding that after a new decision by the plan
fiduciary, a party seeking judicial review in the district court may do so by a timely motion filed
in the same civil action, and is not required to commence a new civil action.”).
2
LaAsmar v. Phelps Dodge Corp. Life, Accidental Death & Dismemberment &
Dependent Life Ins. Plan, 605 F.3d 789, 796 (10th Cir. 2010) (quoting Bard v. Boston Shipping
Ass’n, 471 F.3d 229, 235 (1st Cir. 2006)) (stating that “summary judgment is merely a vehicle
for deciding the case; the factual determination of eligibility for benefits is decided solely on the
administrative record, and the non-moving party is not entitled to the usual inferences in its
favor”).
2
III. CONCLUSION
It is therefore
ORDERED that Plaintiffs’ Motion to Reopen Case (Docket No. 92) is GRANTED. The
Clerk is directed to reopen this case. The parties are directed to file their cross motions for
summary judgment by March 15, 2024.
DATED this 16th day of January, 2024.
BY THE COURT:
Ted Stewart
United States District Judge
3
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?