Campbell v. Unitedhealthcare Insurance Company

── Campbell v. Unitedhealthcare Insurance Company ── Court: Court of Appeals for the Ninth Circuit Date: April 13, 2026 Category: General NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS APR 13 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT LEAH CAMPBELL, No. 24-5736 D.C. No. Plaintiff - Appellant, 2:23-cv-08823-RGK-E and MEMORANDUM* EMSURGCARE, EMERGENCY SURGICAL ASSISTANT, Plaintiffs, v. UNITEDHEALTHCARE INSURANCE COMPANY; INSPERITY, INC., Defendants - Appellees, and DOES, 1-10, Defendant. LEAH CAMPBELL, No. 25-758 Plaintiff - Appellant, D.C. No. 2:23-cv-08823-RGK-E and * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. EMSURGCARE, EMERGENCY SURGICAL ASSISTANT, Plaintiffs, v. UNITEDHEALTHCARE INSURANCE COMPANY; INSPERITY, INC., Defendants - Appellees, and DOES 1-10, Defendant. Appeal from the United States District Court for the Central District of California R. Gary Klausner, District Judge, Presiding Argued and Submitted February 11, 2026 Pasadena, California Before: TALLMAN, VANDYKE, and TUNG, Circuit Judges. Plaintiff-Appellant Leah Campbell appeals the district court’s affirmance of Defendant-Appellees UnitedHealthcare and Insperity’s (together “United”) denial of her claim seeking benefits related to services performed by Emergency Surgical Assistants (“the Assistant Claim”) under the terms of her ERISA health insurance plan (“the Plan”). Campbell also appeals the district court’s denial of her motion for attorneys’ fees and the district court’s judgment declining to impose statutory 2 24-5736 penalties on United. We have jurisdiction under 28 U.S.C. § 1291 and reverse in part, and vacate and remand in part. 1. The district court properly reviewed United’s denial of the Assistant claim under an abuse-of-discretion standard. Review for abuse of discretion is appropriate where, as here, the terms of the Plan contain a discretionary-review clause that “unambiguously provide[s] discretion to the administrator.” Abatie v. Alta Health & Life Ins. Co., 458 F.3d 955, 963 (9th Cir. 2006) (citing Kearney v. Standard Ins. Co., 175 F.3d 1084, 1090 (9th Cir. 1999) (en banc)). 2. But United abused its discretion in denying the Assistant Claim, and we reverse the district court’s judgment to the contrary. Plan administrators abuse their discretion when they fail to engage in “a meaningful dialogue” with beneficiaries or reject a claim without adequate explanation. Booton v. Lockheed Med. Benefit Plan, 110 F.3d 1461, 1463 (9th Cir. 1997); see also Montour v. Hartford Life & Accident Ins. Co., 588 F.3d 623, 630, 636–37 (9th Cir. 2009).1 If benefits are denied in whole or in part, the reason for the denial must be stated in reasonably clear language, with specific reference to the plan provisions that form the basis for the denial; if the plan 1 We conclude that United is a “plan administrator” here. Plan administrators are “the person[s] specifically so designated by the terms of the instrument under which the plan is operated.” 29 U.S.C. § 1002(16)(A). The Plan states: “Your employer and UnitedHealthcare share responsibility for administering the plan,” and lists United and its contact information alongside Campbell’s employer, Insperity. In our view