Cisneros v. UNUM Life Insurance Co. of America

OPINION

TROTT, Circuit Judge:

OVERVIEW

Michelle Cisneros brought this action to recover long-term disability benefits under an ERISA-governed insurance policy (the “Policy”) issued by UNUM Life Insurance Company (“UNUM”). The district court entered summary judgment in favor of UNUM on the ground that Cisneros’s proof-of-claim was untimely under the Policy terms. We agree with the district court’s conclusion that Cisneros failed to comply with the Policy’s unambiguous time-limits for submitting proof-of-claim. However, because we hold that, under California law and federal common law, UNUM is…