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Mark Zavislak v. Netflix, Inc.

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 24-4156, 24-4175 · judgment September 24, 2025


1%
estimated cert probability
(petition-stage, structural)
GVR risk 1%

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

Question presented

ERISA Section 104(b)(4) requires plan administrators to furnish beneficiaries upon written request “any … contract, or other instruments under which the plan is established or operated.” 29 U.S.C. § 1024(b)(4). Nine Courts of Appeals strictly adhere to this statutory text, requiring the disclosure of binding foundational documents that govern a plan’s operation such as claims administration agreements. In acknowledged conflict with its sister circuits, the Ninth Circuit stands alone in applying an atextual information test, allowing fiduciaries to withhold these governing contracts because they do not “provide individual participants with information about the plan and benefits.” The question presented is: Whether a contract that governs the administration of benefit claims is a “contract … under which the plan is established or operated” within the meaning of 29 U.S.C. § 1024(b)(4).

Counsel of record

For petitioner
Oral Shane Balloun
Balloun Law Professional Corporation

For respondent
Aaron Michael Streett
Baker Botts, L.L.P.

Case

Conference history
Distributed for 2 conferences

Linked docket
25A825

Proceedings

  1. Sep 02 2026
  2. Jul 15 2026
    DISTRIBUTED for Conference of 9/28/2026.
  3. Jun 25 2026
    Brief of respondent Netflix, Inc. in opposition filed.
  4. May 19 2026
    Motion to extend the time to file a response is granted and the time is extended to and including June 25, 2026.
  5. May 18 2026
    Motion to extend the time to file a response from May 26, 2026 to June 25, 2026, submitted to The Clerk.
  6. Apr 24 2026
    Response Requested. (Due May 26, 2026)
  7. Apr 15 2026
    DISTRIBUTED for Conference of 5/1/2026.
  8. Apr 07 2026
    Waiver of right of respondent Netflix, Inc. to respond filed.
  9. Mar 24 2026
    Petition for a writ of certiorari filed. (Response due May 1, 2026)
  10. Jan 20 2026
    Application (25A825) granted by Justice Kagan extending the time to file until March 30, 2026.
  11. Jan 13 2026
    Application (25A825) to extend the time to file a petition for a writ of certiorari from January 29, 2026 to March 30, 2026, submitted to Justice Kagan.