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Susan Rene Jones v. Life Insurance Company of North America, et al.

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 16-16172 · judgment November 17, 2017


Certiorari denied · October 1, 2018
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

  1. Do three inconsistent disability determinations supplanted by five inconsistent plan interpretations negate deference or constitute abuse of discretion/bad faith under Conkright’s “one strike” rule?

  2. Is deference to plan interpretations under Conkright’s undefined, “reasonable” safe harbor effectively unlimited? Does it extend to interpretations in litigation counsel’s briefs or of summary plan descriptions (SPDs)?

  3. After Amara, is an SPD evidence of plan meaning or is it meaningless? May an SPD also serve as the plan document? Does an umbrella plan’s incorporation by reference of a long term disability plan’s SPD repeal and replace the actual plan document?

  4. Do 29 U.S.C. 1132(c) penalties apply to administrative record documents defined in 29 C.F.R. 2560.503-1, issued pursuant to express Congressional delegation in 29 U.S.C. 1133?

Counsel of record

For petitioner
Robert B. Nichols Jr.

For respondent
Ronald Keith Alberts
Gordon Rees Scully Mansukhani, LLP

Case

Conference history
Distributed for 1 conference

Linked docket
17A1047

Proceedings

  1. Oct 01 2018
    Petition DENIED. Justice Alito took no part in the consideration or decision of this petition.
  2. Jun 22 2018
    Reply of petitioner Susan Rene Jones filed. (Distributed)
  3. Jun 13 2018
    DISTRIBUTED for Conference of 9/24/2018.
  4. May 31 2018
    Respondents Rule 29.6 Corporate Disclosure Statement received.
  5. May 25 2018
    Brief of respondents Merck Sharp & Dohme, et al. in opposition filed.
  6. Apr 24 2018
    Petition for a writ of certiorari filed. (Response due May 29, 2018)
  7. Mar 29 2018
    Application (17A1047) granted by Justice Kennedy extending the time to file until April 24, 2018.
  8. Mar 21 2018
    Application (17A1047) to extend the time to file a petition for a writ of certiorari from April 9, 2018 to June 8, 2018, submitted to Justice Kennedy.