Archer v. Unum Life Insurance Company of America

CourtDistrict Court, W.D. Washington
DecidedJuly 28, 2025
Docket2:23-cv-01128
StatusUnknown

This text of Archer v. Unum Life Insurance Company of America (Archer v. Unum Life Insurance Company of America) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 PAMELA ARCHER, CASE NO. 2:23-cv-01128-LK 11 Plaintiff, ORDER DENYING PLAINTIFF’S 12 v. MOTION FOR JUDGMENT ON THE RECORD AND GRANTING 13 UNUM LIFE INSURANCE COMPANY DEFENDANT’S CROSS-MOTION OF AMERICA, FOR PARTIAL JUDGMENT ON 14 THE RECORD Defendant. 15 16 This matter comes before the Court on Plaintiff Pamela Archer’s motion for judgment on 17 the record pursuant to Federal Rule of Civil Procedure 52, Dkt. No. 16, and Defendant Unum Life 18 Insurance Company of America’s opposition and cross-motion for partial judgment on the record, 19 Dkt. No. 17.1 Archer alleges that Unum wrongfully terminated her claim for ongoing long-term 20 disability (“LTD”) benefits after learning that she resided in Mexico for more than six months 21 during a 12-month period, in violation of Unum’s policy (the “Policy”). Dkt. No. 1 at 3–4. Archer 22 concedes that she failed to strictly comply with the Policy’s international residency provision, but 23

24 1 Unum does not seek judgment on all of its counterclaims, so its motion is really one for partial judgment on the record. 1 claims that she is entitled to a judgment against Unum under Section 502(a)(1)(B) of the Employee 2 Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1132(a)(1)(B), due to Unum’s failure to 3 continue her disability insurance benefits under the circumstances—namely, the travel challenges 4 she faced during the COVID-19 pandemic. Id. at 7–8; see Dkt. No. 16 at 12–16. She also claims

5 that she is entitled to equitable relief under Section 502(a)(3) of ERISA, 29 U.S.C. § 1132(a)(3), 6 based on Unum’s breach of its fiduciary duties. Dkt. No. 1 at 8–9; Dkt. No. 16 at 16–19. Unum 7 contends that the Policy must be enforced as written, and that based on the plain language of the 8 international residency clause and the undisputed facts of this case, partial judgment should be 9 entered in its favor. Dkt. No. 17 at 3–5, 9–10. 10 For the reasons set forth below, the Court denies Archer’s motion, Dkt. No. 16, and grants 11 Unum’s motion, Dkt. No. 17. The Court further directs the parties to meet and confer and submit 12 a proposed briefing schedule regarding Unum’s counterclaim to recover its alleged overpayment. 13 See Dkt. No. 6 at 10–12; Dkt. No. 17 at 3 n.1, 10; Dkt. No. 20 at 1 n.1. 14 I. STANDARD OF REVIEW

15 The district court reviews a decision to deny benefits under an ERISA plan de novo “unless 16 the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility 17 for benefits or to construe the terms of the plan.” Gatti v. Reliance Standard Life Ins. Co., 415 F.3d 18 978, 981 (9th Cir. 2005) (quoting Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115 19 (1989)). “When the plan gives the administrator or fiduciary discretionary authority to determine 20 eligibility for benefits, that determination is reviewed for abuse of discretion.” Id. “[T]he default 21 is that the administrator has no discretion, and the administrator has to show that the plan gives it 22 discretionary authority in order to get any judicial deference to its decision.” 23 Kearney v. Standard Ins. Co., 175 F.3d 1084, 1089 (9th Cir. 1999) (en banc).

24 1 In this case, while the relevant documents appear to grant Unum “discretionary authority 2 to make benefit determinations under the Plan,” Dkt. No. 15 at 312 (AR 312), Archer asserts— 3 and Unum does not dispute—that de novo review applies, Dkt. No. 16 at 10–11; Dkt. No. 18 at 2; 4 see generally Dkt. Nos. 17, 20. Moreover, since 2009, discretionary clauses like the one at issue

5 here have been deemed unenforceable under Washington law. See Wash. Admin. Code § 284-96- 6 012; Pearson v. Aetna Life Ins. Co., No. C15-0245-JLR, 2016 WL 2745299, at *4 n.9 (W.D. Wash. 7 May 10, 2016); Treves v. Union Sec. Ins. Co., LLC, No. C12-1337-RAJ, 2014 WL 325149, at *2 8 (W.D. Wash. Jan. 29, 2014); see also N.C. v. Premera Blue Cross, 667 F. Supp. 3d 1102, 1106– 9 07 (W.D. Wash. 2023) (noting that “several courts have held that [this] regulation voiding 10 discretionary clauses in disability insurance policies is not preempted by ERISA, making de novo 11 review mandatory for such policies”), aff’d, No. 23-35381, 2024 WL 2862586 (9th Cir. June 6, 12 2024).2 For these reasons, the Court finds that de novo review is appropriate. 13 On de novo review, the Court conducts a bench trial on the record, and makes findings of 14 fact and conclusions of law based on that record. See Walker v. Am. Home Shield Long Term

15 Disability Plan, 180 F.3d 1065, 1069 (9th Cir. 1999) (stating that de novo review applies to the 16 plan administrator’s factual findings as well as plan interpretation). A bench trial may “consist[] 17 of no more than the trial judge rereading [the administrative record.]” Kearney v. Standard Ins. 18 Co., 175 F.3d 1084, 1095 (9th Cir. 1999) (en banc). Accordingly, the Court issues these findings 19 of fact and conclusions of law based on a de novo review of the record. 20 21

22 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), 23 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, 24 1194 (9th Cir. 2007). 1 II. FINDINGS OF FACT 2 Applying de novo review to the administrative record, the Court makes the following 3 findings of fact.3 4 A. Archer’s Employment and Unum’s Initial Award of LTD Benefits

5 1. Archer worked for many years as a nurse, including in the U.S. Army during the 6 first Gulf War. See Dkt. No. 15-1 at 202–04, 493, 529, 661 (AR 1202–04, 1493, 1529, 1661). 7 Archer suffers from post-traumatic stress disorder (“PTSD”) and several chronic orthopedic and 8 medical conditions which impair her functioning. See id. at 474 (AR 1474). 9 2. Due to her combination of ailments, Archer stopped working in October 2012. See 10 Dkt. No. 15 at 5 (AR 5); Dkt. No. 15-1 at 135 (AR 1135). 11 3. Unum issued Group Insurance Policy No. 138177 002 to Archer’s then-employer, 12 Providence Health & Services, as part of Providence’s ERISA employee welfare benefits plan (the 13 “Plan”). See Dkt. No. 15 at 257, 259, 306 (AR 257, 259, 306). 14 4. Based on Archer’s conditions, Unum, as the Plan administrator, approved her claim

15 for LTD benefits in August 2013. See Dkt. No. 15 at 363–69 (AR 363–69). 16 5. Barring a change in her status, Archer remained eligible for LTD benefits until 17 September 2026. Dkt. No. 15 at 855 (AR 855); see also Dkt. No. 15-1 at 32 (AR 1032). 18 B. The Terms of Coverage Provided Under the Policy 19 6.

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