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Subject Matter Jurisdiction and its impact on ERISA claims- N.D. Cal

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  • Subject Matter Jurisdiction and its impact on ERISA claims- N.D. Cal

    In a case coming out of the Northern District of California, Plaintiff brings an ERISA claim against LINA, who then moves for dismissal for lack of subject matter jurisdiction and for failure to state a claim upon which relief can be granted.

    Plaintiff cannot make a prima facie showing that he has suffered an injury that is sufficiently “concrete” to confer standing at present. Plaintiff alleges in his complaint that his right to LTD benefits has been violated. This conclusory allegation, unsupported by facts, need not be accepted as true. Moreover, the allegation is demonstrably false based upon the July 11, 2017 letter granting Plaintiff disability benefits, albeit under the mental disability provision. Plaintiff next argues that the July 11, 2017 letter should be construed as a denial of benefits for his claimed physical impairment because the letter recited that “benefits will cease” at the end of the 24-month mental illness limitation period. Plaintiff’s interpretation of the July 11, 2017 letter is not reasonable. The July 11, 2017 letter does not mention, much less address Plaintiff’s claim for benefits based upon a physical impairment.
    The opinion is attached below.
    Attached Files