Kunin v. Benefit Life Insurance Co.
United States Court of Appeals for the Ninth Circuit
910 F.2d 534 (1990)
Daniel Kunin (plaintiff) incurred over $50,000 in medical bills for treatment of his child’s autism. Benefit Trust Life Insurance Company (Benefit) (defendant) provided a health-insurance policy to Kunin through Kunin’s employer. The policy was an employee-welfare benefit plan governed by the Employee Retirement Income Security Act (ERISA). After Kunin submitted a claim, Benefit agreed to reimburse Kunin for only $10,000, stating that autism fell under the policy’s limit on coverage for mental illness. The policy did not define or explain the term “mental illness” and did not provide any examples of conditions that the term included or excluded. Kunin filed suit in state court, challenging Benefit’s interpretation of the policy. The matter was removed to federal district court on the basis of federal jurisdiction over ERISA. The district court relied on expert testimony to determine the ordinary meaning of the term “mental illness.” Kunin’s experts testified (1) that mental illness referred to a behavioral disturbance with no demonstrably physical basis, arising from reaction to environmental conditions rather than organic causes; (2) that autism would clearly fall outside these criteria for mental illness; and (3) that autism was not a mental illness in the lay or technical senses. The district court concluded that autism was not a mental illness and ordered Benefit to pay Kunin’s claim in full. Benefit appealed.
Rule of Law
Holding and Reasoning (Reinhardt, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 724,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 724,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,600 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.