Stacey Shane began receiving long-term disability benefits after a knee injury prevented her from continuing her job duties. Benefits were approved and paid for an extended period under the plan in effect at the time her disability began.
After a later recertification process, Albertson’s terminated benefits and denied her appeal. The plan argued that later amendments applied retroactively and that discretionary authority supported the termination.
The Ninth Circuit held that the earlier plan governed because it expressly limited amendments to future disabilities. The ruling prevented retroactive application of more restrictive standards and clarified how plan amendments and discretionary authority operate under ERISA.
