Case Explained: RAYA V. BARKA, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-07-28 Docket: 3:19-cv-02295-WQH The ninth circuit affirmed in part, reversed in part, and remanded the district court’s judgment in favor of Defendants in an ERISA action brought by Plaintiff-Appellant Robert Edward Raya. The appellate court held that the district court did not abuse its discretion in admitting untimely exhibits or in finding that Raya knowingly and voluntarily waived his 401(k) Plan and retaliation claims under a separation agreement, applying the nine-factor test from *Schuman v. Microchip Tech Inc.* to determine voluntariness. However, the court reversed the summary judgment dismissing Raya’s Pension Plan claims, ruling that the district court erred by relying on a declaration asserting the authenticity of a 2008 Amendment without addressing evidence suggesting the Amendment was backdated to include an employee hired in 2011. The practical consequence is that Raya’s Pension Plan claims will proceed to trial, while his other claims remain dismissed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.