Unreported / Non-Citable
Background
William Taylor enrolled himself and his family in an employer-sponsored health plan offered through Blue Cross while working for Dele Health Care Tech, Inc., which Vayyar Imaging U.S. Inc. later acquired. After Vayyar terminated Taylor’s employment in September 2023, Taylor said he elected COBRA continuation coverage and continued sending premiums to Total Administrative Service Corporation, which he alleged administered the plan and forwarded payments to Blue Cross.
Taylor alleged that he learned in March 2024 that Blue Cross no longer covered him, that Vayyar had retroactively terminated his coverage effective November 15, 2023, and that Blue Cross owed $31,750 for his medical expenses. He sued Vayyar and Blue Cross under ERISA, but Vayyar was dismissed without prejudice after Taylor failed to serve it. Taylor did not respond to Blue Cross’s dismissal motion or amend his complaint despite an extension, an additional opportunity to amend, and an express warning that failure to amend could foreclose another opportunity.
The Court’s Holding
The court dismissed Taylor’s claim for benefits under 29 U.S.C. § 1132(a)(1)(B), concluding that his allegations were too conclusory to state a plausible claim. Taylor identified no plan terms or representative provisions, supplied no supporting exhibits or meaningful details about the claimed medical expenses, and did not allege that he had tried unsuccessfully to obtain the plan documents. Although an ERISA plaintiff need not always quote specific plan language, the court held that Taylor still had to plead sufficient facts connecting the requested benefits to rights under the plan.
The court also dismissed Taylor’s COBRA-notice claim against Blue Cross because only a plan administrator may be liable under 29 U.S.C. § 1132(c) for violating the notice requirements in § 1166. Taylor’s own complaint identified TASC—not Blue Cross—as the plan administrator. Because Taylor had already declined an opportunity to amend after receiving an explicit warning, the court dismissed all claims against Blue Cross with prejudice. It denied Blue Cross’s alternative motion to strike as moot and declined to decide the insurer’s attorney-fee argument.
Key Takeaways
- An ERISA benefits complaint must plead enough facts to plausibly connect the benefits sought to rights provided by the governing plan, even when quoting every relevant plan provision is unnecessary.
- A plaintiff’s inability to obtain plan documents may help explain the absence of specific plan language, but Taylor alleged neither efforts to obtain the documents nor representative plan provisions.
- A COBRA-notice claim seeking liability under § 1132(c) must be brought against the plan administrator; Taylor’s allegations established that Blue Cross did not hold that role.
Why It Matters
The decision illustrates the factual detail needed to sustain an ERISA benefits claim at the pleading stage. Allegations that coverage ended despite continued premium payments, without supporting plan terms, representative provisions, benefit-claim details, or an explanation for the absence of plan documents, may not suffice.
It also underscores the importance of identifying the legally responsible entity in COBRA litigation and responding to opportunities to amend. Taylor’s failure to amend after the court’s warning resulted in dismissal with prejudice rather than another chance to replead against Blue Cross.