The claimant sought ERISA life insurance benefits after Lincoln Life denied a claim following a death. The denial left the beneficiary without payment under a policy intended to provide post-loss financial protection.
In litigation, Lincoln Life attempted to defend its decision using explanations that were not fully articulated in the administrative denial. Kantor & Kantor argued that the insurer was improperly supplementing the record with post-hoc rationales.
The Ninth Circuit held that ERISA review is limited to the reasons actually stated during the claims process and rejected Lincoln Life’s attempt to rely on new explanations. The ruling reinforced that insurers must fully and honestly explain their denials at the administrative stage.
