The claimant sought continued inpatient psychiatric treatment for major depressive disorder (recurrent), dissociative identity disorder, post-traumatic stress disorder, and bulimia. Treating psychiatrists documented dissociative episodes, eating-disorder behaviors, and a high risk of decompensation without structured inpatient care.
The insurer initially approved inpatient treatment from May 11, 2004 through August 29, 2004, then denied further coverage, asserting the claimant could transition to outpatient care based on selective symptom improvement. The denial discounted treating-provider assessments documenting ongoing instability and relapse risk.
Applying California’s Mental Health Parity Act and conducting de novo review, the court held that the claimant was entitled to continued inpatient benefits. The decision limited insurers’ ability to downgrade care for serious mental health conditions while continuing to cover comparable medical treatment.
