Smith v. Medical Benefit Administrators Group, Inc.

Dist. Ct. did not err in dismissing portion of plaintiff's ERISA action seeking damages associated with medical bills incurred by plaintiff while undergoing bypass surgery, where plaintiff alleged that defendant-benefit plan preauthorized said surgery but then notified plaintiff after his surgery that said surgery was not covered under medical plan. Plaintiff could not obtain legal relief in form of monetary damages under section 502(a)(1) of ERISA since plaintiff conceded that instant plan did not cover said surgery. However, plaintiff could seek certain forms of equitable relief, and Dist. Ct. erred in dismissing portion of complaint seeking declaratory and injunctive relief in terms with respect to defendant's alleged practice of delaying responses to preauthorization requests or misleading plan participants into believing that preauthorization constituted determination that claim will be paid.