Pennsylvania Chiropractic Association v. Independence Hospital Indemnity Plan, Inc.

In ERISA action by plaintiffs-chiropractors and others alleging that defendant-insurance company used wrong procedure when determining how much to pay plaintiffs for services rendered to patients under health plan, Dist. Ct. erred in finding that plaintiffs were “beneficiaries” of health plan so as to entitle them to bring instant action under ERISA. Section 1132(a)(1)(B) grants to plan participants or beneficiaries ability to enforce in federal court instant procedure sought by plaintiffs. However, plaintiffs conceded that they were not participants of plan as defined in section 29 USC section 1002(7), and record showed that plaintiffs were not “beneficiaries” of plan where they did not show either that they had been designated by any participant in terms of assignment of claim or had been designated as participant in any employee benefit plan. As such, plaintiffs could only bring instant action in state court.