Case Explained: ROGGENKAMP V. MORGAN STANLEY MEDICAL PLAN

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-05 Docket: 2:23-cv-05531-WLH-AGR The ninth-circuit affirmed the district court’s conclusion that Cigna did not operate under a conflict of interest, but reversed and remanded the judgment denying benefits to Marc Roggenkamp for failure to provide a full and fair review under the Employee Retirement Income Security Act (ERISA). The court applied an abuse of discretion standard of review because the plan granted Cigna discretionary authority to determine eligibility. Regarding the conflict of interest claim, the court held that Roggenkamp failed to meet his burden of producing evidence showing that Cigna both determined eligibility and paid for benefits, as Morgan Stanley funded the plan; thus, no financial conflict existed to warrant less deference. However, the court found the district court erred in affirming the denial because Cigna relied solely on an internal non-plan document (Medical Coverage Policy No. 0104) rather than the governing Summary Plan Description (SPD). The court ruled that relying on the SPD’s definition of “experimental” for the first time during litigation constituted an impermissible post-hoc rationalization that deprived Roggenkamp of the opportunity to respond, violating ERISA’s requirement for specific reasons in denial notices. Furthermore, the court determined Cigna abused its discretion by failing to meaningfully address information provided during appeals and by not interpreting the SPD’s plain language regarding experimental services. Consequently, the case is remanded with instructions for Cigna to reevaluate the merits of Roggenkamp’s claim based on the SPD definition rather than the internal policy exclusion. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.