The U.S. Court of Appeals for the Second Circuit affirmed a district court's summary judgment ruling in favor of Rabobank Medical Plan on Feb. 5, 2026, in a case involving disputed employee benefits claims from the estate of a deceased plan participant.
Sheri Savage, serving as executrix of her deceased sister Cindy Sieden's estate and aunt to J.S., had appealed the U.S. District Court for the Southern District of New York's Sept. 30, 2024 judgment that granted summary judgment to the medical plan. The three-judge panel of Circuit Judges Guido Calabresi, Reena Raggi, and Eunice C. Lee issued a summary order affirming the lower court's decision.
The case, *Savage v. Rabobank Medical Plan* (No. 24-2759-cv), represents another example of ongoing litigation between beneficiaries and employer-sponsored health plans over coverage determinations and benefit disputes under the Employee Retirement Income Security Act.
Savage was represented by Elizabeth K. Green of Green Health Law APC in Glendale, California, and Elizabeth Hopkins of Kantor & Kantor, LLP in Northridge, California. The medical plan was represented by John Houston Pope of Epstein Becker & Green, P.C. in New York.
The Second Circuit's ruling came in the form of a summary order, which under federal court rules does not carry precedential effect. The court noted that such rulings may be cited in documents filed with the court, but parties must reference either the Federal Appendix or an electronic database with the notation "summary order."
The brief nature of the appellate court's order suggests the panel found no reversible error in District Judge Paul G. Gardephe's analysis of the case. Summary orders are typically used when the legal issues are straightforward and do not require extensive written analysis.
Employee benefits litigation under ERISA has become increasingly common as plan participants and beneficiaries challenge denials of coverage, disputes over plan interpretations, and other benefit-related decisions. These cases often involve complex questions about plan administration, fiduciary duties, and the scope of benefits coverage.
The involvement of an estate executor in this case indicates the dispute likely arose from benefits claims related to the deceased plan participant's medical coverage or survivor benefits. Estate executors frequently must navigate complex benefit systems to secure coverage for final medical expenses or to obtain benefits owed to surviving family members.
ERISA provides a framework for employee benefit plans but also establishes specific procedures for challenging plan decisions. Plan participants typically must exhaust administrative remedies before pursuing federal court litigation. The law generally provides plan administrators with significant discretion in interpreting plan terms, making it challenging for participants to successfully challenge adverse benefit decisions.
The case was heard at the Thurgood Marshall United States Courthouse in New York City, the Second Circuit's primary courthouse located at 40 Foley Square. The Second Circuit has jurisdiction over federal appeals from courts in New York, Connecticut, and Vermont.
While the specific details of the underlying dispute are not detailed in the summary order, the case appears to follow typical patterns in ERISA litigation where beneficiaries challenge plan administrators' decisions regarding coverage or benefit payments. Such disputes often center on plan interpretation, medical necessity determinations, or eligibility requirements.
The affirmance suggests the district court properly applied ERISA standards in evaluating the medical plan's actions. Federal courts reviewing ERISA benefit decisions typically apply either a de novo standard of review or a more deferential arbitrary and capricious standard, depending on whether the plan grants discretionary authority to the administrator.
For estate planning and employee benefits practitioners, the case serves as a reminder of the challenges facing beneficiaries who seek to challenge employer-sponsored benefit plan decisions in federal court. The procedural requirements under ERISA, combined with the often deferential review standards applied by courts, can create significant hurdles for participants and beneficiaries.
The case also highlights the importance of careful plan administration and documentation by employers and their benefit plan providers. Clear plan language and thorough administrative records can help defend against participant challenges in federal litigation.
Neither party has announced plans for further appeals. Under federal appellate procedure, Savage would need to seek Supreme Court review through a petition for certiorari, though the high court accepts only a small percentage of such requests and typically focuses on cases involving significant legal questions or circuit splits.