9th Circuit: Preauthorization Request Must Be Evaluated Under ERISA Plan Document

( June 10, 2026, 9:15 AM EDT) -- PASADENA, Calif. — In an unpublished memorandum disposition partly reversing and remanding judgment in favor of a health plan over refusal to preauthorize “a two-level artificial disc replacement surgery,” the Ninth Circuit U.S. Court of Appeals affirmed that the administrator “did not operate under a conflict of interest,” then ruled that the administrator erred in denying the claim and the bench trial judge erred in finding no abuse of discretion on the administrator’s part....