Court Can’t Predict Employee’s Future
An employee insured under her employer’s welfare benefit plan sued a life-insurance provider seeking, (1) a ruling enforcing the plan’s waiver of its premium provision, allowing a covered person who becomes “Totally Disabled” while insured to remain eligible for coverage without paying premiums, and (2) a declaration as to future eligibility of benefits, that the insured had provided sufficient information to the insurer to be deemed totally disabled as defined by terms of the ERISA-governed insurance plan. After ping-ponging in the lower court, the Court of Appeals held the insured was not entitled to coverage pursuant to a waiver of the premium provision because it was moot. She was also not entitled to a declaration as to future eligibility for benefits. The court reasoned that without an adverse benefits determination, there was no ripe claim before it.