Archer v. Unum Life Insurance Company of America

District Court, W.D. Washington·Decided July 28, 2025·No. 2:23-cv-01128·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE PAMELA ARCHER, CASE NO. 2:23-cv-01128-LK Plaintiff, ORDER DENYING PLAINTIFF’S v. MOTION FOR JUDGMENT ON THE RECORD AND GRANTING UNUM LIFE INSURANCE COMPANY DEFENDANT’S CROSS-MOTION OF AMERICA, FOR PARTIAL JUDGMENT ON Defendant. This matter comes before the Court on Plaintiff Pamela Archer’s motion for judgment on the record pursuant to Federal Rule of Civil Procedure 52, Dkt. No. 16, and Defendant Unum Life Insurance Company of America’s opposition and cross-motion for partial judgment on the record, Dkt. No. 17.1 Archer alleges that Unum wrongfully terminated her claim for ongoing long-term disability (“LTD”) benefits after learning that she resided in Mexico for more than six months during a 12-month period, in violation of Unum’s policy (the “Policy”). Dkt. No. 1 at 3–4. Archer concedes that she failed to strictly comply with the Policy’s international residency provision, but

1 Unum does not seek judgment on all of its counterclaims, so its motion is really one for partial judgment on the record. claims that she is entitled to a judgment against Unum under Section 502(a)(1)(B) of the Employee Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1132(a)(1)(B), due to Unum’s failure to continue her disability insurance benefits under the circumstances—namely, the travel challenges she faced during the COVID-19 pandemic. Id. at 7–8; see Dkt. No. 16 at 12–16. She also claims

that she is entitled to equitable relief under Section 502(a)(3) of ERISA, 29 U.S.C. § 1132(a)(3), based on Unum’s breach of its fiduciary duties. Dkt. No. 1 at 8–9; Dkt. No. 16 at 16–19. Unum contends that the Policy must be enforced as written, and that based on the plain language of the international residency clause and the undisputed facts of this case, partial judgment should be entered in its favor. Dkt. No. 17 at 3–5, 9–10. For the reasons set forth below, the Court denies Archer’s motion, Dkt. No. 16, and grants Unum’s motion, Dkt. No. 17. The Court further directs the parties to meet and confer and submit a proposed briefing schedule regarding Unum’s counterclaim to recover its alleged overpayment. See Dkt. No. 6 at 10–12; Dkt. No. 17 at 3 n.1, 10; Dkt. No. 20 at 1 n.1.

The district court reviews a decision to deny benefits under an ERISA plan de novo “unless the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan.” Gatti v. Reliance Standard Life Ins. Co., 415 F.3d 978, 981 (9th Cir. 2005) (quoting Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115 (1989)). “When the plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits, that determination is reviewed for abuse of discretion.” Id. “[T]he default is that the administrator has no discretion, and the administrator has to show that the plan gives it discretionary authority in order to get any judicial deference to its decision.” Kearney v. Standard Ins. Co., 175 F.3d 1084, 1089 (9th Cir. 1999) (en banc).

In this case, while the relevant documents appear to grant Unum “discretionary authority to make benefit determinations under the Plan,” Dkt. No. 15 at 312 (AR 312), Archer asserts— and Unum does not dispute—that de novo review applies, Dkt. No. 16 at 10–11; Dkt. No. 18 at 2; see generally Dkt. Nos. 17, 20. Moreover, since 2009, discretionary clauses like the one at issue

here have been deemed unenforceable under Washington law. See Wash. Admin. Code § 284-96- 012; Pearson v. Aetna Life Ins. Co., No. C15-0245-JLR, 2016 WL 2745299, at *4 n.9 (W.D. Wash. May 10, 2016); Treves v. Union Sec. Ins. Co., LLC, No. C12-1337-RAJ, 2014 WL 325149, at *2 (W.D. Wash. Jan. 29, 2014); see also N.C. v. Premera Blue Cross, 667 F. Supp. 3d 1102, 1106– 07 (W.D. Wash. 2023) (noting that “several courts have held that [this] regulation voiding discretionary clauses in disability insurance policies is not preempted by ERISA, making de novo review mandatory for such policies”), aff’d, No. 23-35381, 2024 WL 2862586 (9th Cir. June 6, 2024).2 For these reasons, the Court finds that de novo review is appropriate. On de novo review, the Court conducts a bench trial on the record, and makes findings of fact and conclusions of law based on that record. See Walker v. Am. Home Shield Long Term

Disability Plan, 180 F.3d 1065, 1069 (9th Cir. 1999) (stating that de novo review applies to the plan administrator’s factual findings as well as plan interpretation). A bench trial may “consist[] of no more than the trial judge rereading [the administrative record.]” Kearney v. Standard Ins. Co., 175 F.3d 1084, 1095 (9th Cir. 1999) (en banc). Accordingly, the Court issues these findings of fact and conclusions of law based on a de novo review of the record.

2 Although the Policy went into effect in 2007 and the Washington regulation prohibiting discretionary clauses went into effect in 2009, Unum issued an amended version of the Policy in 2012, Dkt. No. 15 at 256–57 (AR 256–257), making the regulation applicable here, see, e.g., Rustad-Link v. Providence Health & Servs., 306 F. Supp. 3d 1224, 1233–35 (D. Mont. 2018) (collecting cases from this district). In any event, the Court notes that it would reach the same outcome in this case under an abuse of discretion standard. See, e.g., Gilliam v. Nev. Power Co., 488 F.3d 1189, 1194 (9th Cir. 2007). Applying de novo review to the administrative record, the Court makes the following findings of fact.3 A. Archer’s Employment and Unum’s Initial Award of LTD Benefits

1. Archer worked for many years as a nurse, including in the U.S. Army during the first Gulf War. See Dkt. No. 15-1 at 202–04, 493, 529, 661 (AR 1202–04, 1493, 1529, 1661). Archer suffers from post-traumatic stress disorder (“PTSD”) and several chronic orthopedic and medical conditions which impair her functioning. See id. at 474 (AR 1474). 2. Due to her combination of ailments, Archer stopped working in October 2012. See Dkt. No. 15 at 5 (AR 5); Dkt. No. 15-1 at 135 (AR 1135). 3. Unum issued Group Insurance Policy No. 138177 002 to Archer’s then-employer, Providence Health & Services, as part of Providence’s ERISA employee welfare benefits plan (the “Plan”). See Dkt. No. 15 at 257, 259, 306 (AR 257, 259, 306). 4. Based on Archer’s conditions, Unum, as the Plan administrator, approved her claim

for LTD benefits in August 2013. See Dkt. No. 15 at 363–69 (AR 363–69). 5. Barring a change in her status, Archer remained eligible for LTD benefits until September 2026. Dkt. No. 15 at 855 (AR 855); see also Dkt. No. 15-1 at 32 (AR 1032). B. The Terms of Coverage Provided Under the Policy 6. As relevant here, the Policy included the following provision: WHEN WILL PAYMENTS STOP?

We will stop sending you payments and your claim will end on the earliest of the following:

Free access — add to your briefcase to read the full text and ask questions with AI

Archer v. Unum Life Insurance Company of America, (W.D. Wash. 2025).

Archer v. Unum Life Insurance Company of America (Archer v. Unum Life Insurance Company of America) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Massachusetts Mutual Life Insurance v. Russell
473 U.S. 134 (Supreme Court, 1985)
Firestone Tire & Rubber Co. v. Bruch
489 U.S. 101 (Supreme Court, 1989)
Aetna Health Inc. v. Davila
542 U.S. 200 (Supreme Court, 2004)
Barrs v. Lockheed Martin Corp.
287 F.3d 202 (First Circuit, 2002)
Margaret Krohn v. Huron Memorial Hospital
173 F.3d 542 (Sixth Circuit, 1999)
Jeanene Harlick v. Blue Shield of California
686 F.3d 699 (Ninth Circuit, 2012)
Mark Stephan v. Unum Life Insurance Company Of
697 F.3d 917 (Ninth Circuit, 2012)
U.S. Airways, Inc. v. McCutchen
133 S. Ct. 1537 (Supreme Court, 2013)
Scharff v. Raytheon Co. Short Term Disability Plan
581 F.3d 899 (Ninth Circuit, 2009)
Heimeshoff v. Hartford Life & Accident Ins. Co.
134 S. Ct. 604 (Supreme Court, 2013)
Stephen Bafford v. Northrop Grumman Corp.
994 F.3d 1020 (Ninth Circuit, 2021)
Henry v. Himes
14 F. Supp. 3d 1036 (S.D. Ohio, 2014)
Rustad-Link v. Providence Health & Servs.
306 F. Supp. 3d 1224 (D. Montana, 2018)