The U.S. Court of Appeals for the Ninth Circuit issued a memorandum decision Tuesday in a significant Employee Retirement Income Security Act class action involving more than 50 plaintiffs who challenged benefit denials by the ILWU-PMA Welfare Plan.
The case, *Delgado v. ILWU-PMA Welfare Plan*, involves participants in the multiemployer benefit plan who received treatment at the Advanced Pain Treatment Medical Center, a surgical clinic in San Pedro, California. The plaintiffs brought claims against the plan for unpaid benefits under ERISA.
Lead plaintiff Angelina Bowen Delgado and dozens of other named plaintiffs, including Robin Becerra, Steve Bozan, Diana Brown, and Jean Cigiliano, among others, filed the lawsuit in 2018 in the U.S. District Court for the Central District of California. The case was assigned to District Judge Consuelo B. Marshall.
The ILWU-PMA Welfare Plan is an employee health and welfare plan established under ERISA, the federal law that governs employer-sponsored benefit plans. The International Longshore and Warehouse Union-Pacific Maritime Association plan provides health and welfare benefits to longshore workers and their families along the West Coast.
The dispute centers on medical treatments the plaintiffs received at APTMC. According to court documents, each plaintiff received treatment at the San Pedro facility, but the plan denied coverage for the services. The nature of the treatments and the plan's specific reasons for denial are not detailed in the available court filing.
The case proceeded through the district court, where Judge Marshall presided over the litigation. The appeals court heard oral arguments on Nov. 20, 2025, in Pasadena, California, before a three-judge panel consisting of Circuit Judges Kim McLane Wardlaw, N.R. Smith, and Douglas Miller.
Notably, the decision included a dissent by Judge N.R. Smith, suggesting the panel was not unanimous in its ruling. The presence of a dissenting opinion indicates disagreement among the judges about either the legal analysis or the outcome of the case.
The Ninth Circuit issued its decision as a memorandum, which means it is not designated for publication and does not create binding precedent except as provided by Ninth Circuit Rule 36-3. This limitation means the decision will have minimal impact on future ERISA litigation beyond the immediate parties to this case.
ERISA cases involving multiemployer plans like the ILWU-PMA Welfare Plan often involve complex questions about benefit eligibility, coverage determinations, and the scope of plan discretion in making benefit decisions. These plans typically serve workers in industries where employees may work for multiple employers over their careers, such as construction, transportation, and maritime work.
The ILWU represents workers at ports along the Pacific Coast, and the PMA represents shipping companies and terminal operators. Their jointly administered welfare plan provides health benefits to thousands of longshore workers and their families. Disputes over coverage decisions in such plans can affect large numbers of workers and their access to medical care.
The case highlights ongoing tensions in ERISA litigation between plan participants seeking coverage for medical treatments and benefit plans that make coverage determinations based on plan terms and administrative policies. Federal courts regularly review these disputes under ERISA's framework for challenging benefit denials.
ERISA provides specific procedures for participants to challenge benefit denials, including requirements for internal appeals and standards for judicial review. Courts typically review plan decisions under either an arbitrary and capricious standard or de novo review, depending on whether the plan grants discretionary authority to plan administrators.
The original lawsuit was filed in 2018 and assigned case number 2:18-cv-05539-CBM-E in the Central District of California. The case took several years to reach the appeals court level, reflecting the often lengthy nature of ERISA litigation.
The memorandum decision was filed Jan. 21, 2026, and assigned appellate case number 24-1845. The specific outcome of the appeal and whether the plaintiffs prevailed in their claims for unpaid benefits is not detailed in the available court filing.
The case represents one of many ERISA disputes that reach federal appeals courts each year. These cases often involve technical questions about plan interpretation, coverage decisions, and the administrative processes required under federal benefits law.
For the plaintiffs involved, the case represents years of litigation over access to medical benefits. For the broader longshore community served by the ILWU-PMA Welfare Plan, the case may provide guidance about coverage policies and the plan's approach to benefit determinations.
The involvement of more than 50 named plaintiffs suggests the dispute may have affected a significant number of plan participants who received similar treatments at the Advanced Pain Treatment Medical Center or faced similar coverage denials from the plan.