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United States Ninth Circuit

Spinedex Physical Therapy v. United Healthcare, 12-17604

In this action brought by health provider Spinedex, an assignee and would-be assignee of health plan beneficiaries seeking payment of denied benefit claims under the Employee Retirement Income Security Act (ERISA), summary judgment in favor of defendants is reversed in part, affirmed in part, vacated in part, and remanded, where: 1) Spinedex had Article III standing as assignee of plan beneficiaries to bring benefits claims against defendants; 2) Spandex was not assigned the right to bring claims for breach of fiduciary duty; 3) plaintiff ACS does not have associational standing to bring suit against defendant United Healthcare; 4) plaintiff Adams' breach of fiduciary duty claim is time-barred; 5) Spinedex's claims as assignee of beneficiaries under the Martz Agency Plan and the Acoustic Technologies Plan are not time-barred; 6) the anti-assignment provision of the Discount Tire Plan precluded assignment to Spinedex; 7) plaintiff Aragon's claim for breach of fiduciary duty was not exhausted; and 8) United Healthcare was a proper defendant for benefit claims under the American Express Plan.

Appellate Information

  • Decided 11/05/2014
  • Published 11/05/2014


  • Fletcher


  • United States Ninth Circuit


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