P. v. United Healthcare Benefits Plan of California
- Richard Seeborg
- 3:24-cv-06932
- U.S. District Court · Northern District of California
- 3
In Ethan P. v. United Healthcare, Judge Seeborg granted a motion to dismiss with leave to amend parity-act allegations in an employee-benefits claim.
Ethan P.’s claims against United Healthcare Benefits Plan of California were affected. The order removed the mental-health parity-law allegations from the fiduciary-duty claim unless Ethan P. files an amended complaint within 14 days; the benefits claim and other fiduciary-duty allegations were not dismissed by this order.
What happened
In Ethan P. v. United Healthcare Benefits Plan of California, Ethan P. alleged that the plan violated federal employee-benefits law by refusing to cover medically necessary mental-health treatment for his son. The plan did not challenge Ethan P.’s claim seeking payment of benefits at this stage.
The plan challenged only the part of Ethan P.’s separate fiduciary-duty claim based on alleged violations of California and federal mental-health parity laws. Ethan P. defended other grounds for his fiduciary-duty claim but did not substantially dispute that the complaint lacked facts supporting the parity-law allegations.
Judge Seeborg granted the motion to dismiss with leave to amend, but only as to the parity-law allegations. Ethan P. may file an amended complaint within 14 days; otherwise, the fiduciary-duty claim will continue without those allegations.
The detailed version
- P. v. United Healthcare Benefits Plan of California · No. 3:24-cv-06932
- Richard Seeborg
- Feb. 11, 2025
Background
Ethan P. sued United Healthcare Benefits Plan of California under the Employee Retirement Income Security Act of 1974 (ERISA). He alleged that United Healthcare refused to cover certain mental-health treatment for his son, even though the treatment was medically necessary and otherwise eligible for coverage under the employer-sponsored welfare benefit plan in which he participated.
The First Amended Complaint included a claim seeking recovery of benefits and a second claim labeled “breach of fiduciary duty.” The benefits claim was not challenged in the motion addressed by this order. The fiduciary-duty claim included allegations that United Healthcare violated California’s Mental Health Parity Act and the federal Mental Health Parity and Addiction Equity Act of 2008.
Parties’ Positions
United Healthcare did not ask the court to dismiss the fiduciary-duty claim in its entirety. It argued that the First Amended Complaint did not allege enough facts to state a claim based on violations of either the state or federal mental-health parity laws.
Ethan P. argued that he had adequately alleged breach of fiduciary duty on other grounds. The order states that he offered no real defense of the complaint’s allegations that the denial of benefits violated the parity laws.
Court’s Analysis
The court concluded that the First Amended Complaint failed to state a claim for violation of the state and federal mental-health parity laws. Because those allegations formed part of the fiduciary-duty claim, the court dismissed that claim only to the extent it was based on alleged parity-law violations. The court did not dismiss the fiduciary-duty claim in full and did not dismiss the separate claim seeking recovery of benefits.
Disposition
The court granted United Healthcare’s motion to dismiss with leave to amend. If Ethan P. files an amended complaint within 14 days of the order, he may pursue a claim based on parity-law violations in addition to the other allegations he says constitute breach of fiduciary duty. If he does not file an amended complaint, the case will proceed on the First Amended Complaint without any claim that the denial of benefits violated the state or federal parity laws. The court also vacated the scheduled hearing because it found the motion suitable for decision without oral argument.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.