Hints v. American Family Life Assurance Company of Columbus
- Yvonne Rogers
- 4:19-cv-03764
- U.S. District Court · Northern District of California
- 3
In Hints v. American Family, Judge Rogers approved final judgment, dismissing the entire action on the merits after Hints conceded his remaining claim could not succeed.
Ralph F. Hints and American Family Life Assurance Company of Columbus. Hints was ordered to recover nothing, and the entire action was dismissed on the merits.
What happened
Ralph F. Hints sued American Family Life Assurance Company of Columbus over disability-insurance benefits under federal employee-benefits law. He sought a declaration about future benefits and equitable relief based on alleged representations by the insurer’s personnel.
The court had already ruled for the insurer on Hints’s benefits claim, finding that the policy was unambiguous as applied to his situation. Hints then agreed that his remaining claim could not succeed under Ninth Circuit law, while reserving the possibility of bringing it again if an appeals court later reversed or vacated the policy ruling.
The court approved the parties’ joint request for a final, appealable judgment under Rule 41(a)(2). Judge Yvonne Gonzalez Rogers ordered that Hints recover nothing from the insurer and that the entire action be dismissed on the merits.
The detailed version
- Hints v. American Family Life Assurance Company of Columbus · No. 4:19-cv-03764
- Yvonne Rogers
- July 27, 2020
Background
Ralph F. Hints’s complaint asserted two claims against American Family Life Assurance Company of Columbus (AFLAC) concerning a disability-insurance policy. The first claim sought a judicial declaration of Hints’s rights to future benefits under the policy under 29 U.S.C. § 1132(a)(1)(B). The second sought equitable relief based on estoppel, a theory that can prevent a party from taking a position inconsistent with its earlier representations, under 29 U.S.C. § 1132(a)(3).
Earlier ruling and stipulation
On May 15, 2020, the court granted judgment on the pleadings for AFLAC on the first claim. Judgment on the pleadings is a decision based on the parties’ pleadings rather than a trial. The court determined that the policy was unambiguous as applied to Hints’s situation.
Hints stated that, under Ninth Circuit law, an estoppel claim under § 1132(a)(3) requires ambiguity in the relevant plan provisions. Based on the court’s finding that the policy was unambiguous, Hints conceded that his second claim could not succeed and was without merit under that law. He stipulated that the second claim could be asserted after a future Ninth Circuit mandate only if the ruling that the policy was unambiguous were reversed or otherwise vacated, along with satisfaction of all other applicable requirements.
Hints sought a final, appealable judgment so he could seek appellate review of the policy-interpretation ruling. The parties jointly requested entry of judgment under Federal Rule of Civil Procedure 41(a)(2), and the court stated that it was willing to enter a stipulated dismissal under that rule.
Ruling
The court approved the parties’ request after stating that it had meaningfully participated in securing entry of a final and appealable judgment. Judge Yvonne Gonzalez Rogers ordered that Hints recover nothing from AFLAC, that the entire action be dismissed on the merits, and that final judgment be entered accordingly.
Disposition
The court granted the stipulated request for entry of final judgment and dismissed the entire action on the merits. The opinion does not state that the dismissal was with or without prejudice.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.