Cyr v. Reliance Standard Life Insurance, 642 F.3d 1202

Cyr, CTI employee, received long-term disability benefits funded by Reliance under a CTI program; Reliance controlled benefit-denial decisions but was not identified as plan administrator.
Cyr was terminated in Oct 2000 and filed for disability; Reliance approved benefits at a salary of $85,000 and continued paying based on that figure.
Cyr later settled a gender-discrimination claim with CTI, retroactively increasing her salary to $155,000 one week before termination; Cyr requested increased benefits from Reliance.
Reliance acknowledged via its representative that increased benefits would be paid if bona fide but later refused to pay the higher amount.
Cyr sued Reliance, the Plan, and CTI as plan administrator, asserting ERISA §1132(a)(1)(B) benefits recovery, equitable estoppel, and fiduciary breach.
The district court initially granted summary judgment for Reliance on the ERISA claim but later granted summary judgment for Cyr, treating Reliance as potentially liable, then the case was en banc reconsidered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Who may be sued under ERISA §1132(a)(1)(B) for benefits	Cyr argues insurer can be proper defendant.	Reliance contends only plan or plan administrator may be sued.	Insurer may be a proper defendant under §1132(a)(1)(B).

Harris Trust & Savings Bank v. Salomon Smith Barney, Inc., 530 U.S. 238 (2000) (no limit on who may be sued under §1132(a)(3))
Ford v. MCI Communications Corp. Health & Welfare Plan, 399 F.3d 1076 (9th Cir. 2005) (overruled on point of defendant scope under §1132(a)(1)(B))
Everhart v. Allmerica Financial Life Insurance Co., 275 F.3d 751 (9th Cir. 2001) (limitation on who may be sued under ERISA discussed)
Spain v. Aetna Life Insurance Co., 13 F.3d 310 (9th Cir. 1993) (ERISA defendant scope considerations)
Gelardi v. Pertec Computer Corp., 761 F.2d 1323 (9th Cir. 1985) (precedent on ERISA defendant identity)