Case Explained: MEYER V. UNITEDHEALTHCARE INSURANCE COMPANY, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-16 Docket: 9:21-cv-00148-DLC The Ninth Circuit affirmed the district court’s dismissal of John Philip Meyer’s putative class action complaint alleging violations of the Employee Retirement Income Security Act of 1974 (ERISA). The court reviewed the dismissal de novo under Federal Rule of Civil Procedure 12(b)(6), applying the standard that a complaint must contain sufficient factual matter to state a claim for relief that is plausible on its face. The court held that Meyer failed to plead a cognizable breach of fiduciary duty claim because he did not allege sufficient facts demonstrating that UnitedHealthcare Insurance Company breached any fiduciary duty owed to him. Specifically, the court noted that the district court correctly determined the No Surprises Act did not apply to the case as the challenged conduct occurred before the Act’s effective date of January 1, 2022. Because the complaint was dismissed for failure to state a claim under ERISA, the appellate court declined to address the district court’s alternative ruling regarding the three-year statute of limitations for breach of fiduciary duty claims under 29 U.S.C. § 1113(2). As a result of this decision, the dismissal of Meyer’s complaint with prejudice stands, and no further proceedings on the merits of the ERISA claims are permitted. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.