9th Cir.;
15-56371

The court of appeals reversed a district court judgment. The court held that an insured's employer acted as the insurer's agent in waiving the eligibility requirement for coverage under an ERISA-governed benefits plan.

Susan Salyers bought a $250,000 life insurance policy on her husband through an ERISA-governed benefits plan administered by her employer, Providence Health & Services. Providence deducted premiums from Salyers' paycheck commensurate with that amount of coverage. When Salyers's husband died, Metropolitan Life Insurance Company (MetLife) paid out only $30,000. It refused to pay the full $250,000 because Salyers had not submitted evidence of insurability with her coverage election, as required under the plan for coverage over $50,000. After unsuccessfully appealing the denial of benefits through MetLife's administrative process, Salyers filed suit against MetLife.