United States Second Circuit

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New York State Psychiatric Association, Inc. v. UnitedHealth Group, 14-20

In an action under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. sections 1132(a)(1)(B), (a)(3), claiming that healthcare-defendant had violated its fiduciary duties under ERISA, the terms of ERISA-governed health insuance plans administered by defendant, and the Mental Health Parity and Addiction Equity Act of 2008 (Parity Act), the district court's grant of defendant's motion to dismiss is: 1) affirmed in part as to dismissal of Dr. Menolascino's claims because the amended complaint's allegations relating to those claims fail to satisfy the Twombly pleading standard; and 2) vacated in part as to the dismissal on standing grounds of NYSPA's claims, and dismissal of Denbo's claims under section 502(a)(3) on the grounds that section 502(a)(1)(B) provides Denbo with adequate relief.

Appellate Information

  • Decided 08/20/2015
  • Published 08/20/2015


  • Lohier


  • United States Second Circuit