David and Carolyn Gaskell v. The Harvard Cooperative Society, David and Carolyn Gaskell v. The Harvard Cooperative Society

CYR, Circuit Judge.

This case presents several important issues relating to group health plan “continuation coverage” under the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1001 et seq., as amended by the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”), P.L. 99-272, 100 Stat. 82, 222 (1986). The district court ruled that plaintiff Carolyn Gaskell, wife of “covered employee” David Gaskell, was entitled to three years’ continuation coverage under COBRA, dating from her election of continuation coverage under an ERISA employer-sponsored group health…