"After reviewing both the certificate of coverage and the SPD, the Ninth Circuit determined that they were ambiguous as to exactly when the employee's 31-day conversion period began.... The court also observed that the employer: [1] had continued to pay premiums for the employee after February 29 (thereby increasing the potential for confusion on when the 31-day conversion period began); and [2] was aware of the employee's terminal condition, and should have realized that the employee would be interested in maintaining his life insurance coverage." [Estate of Foster v. American Marine SVS Group Benefit Plan, No. 20-35023 (9th Cir. Feb. 9, 2021)]  MORE >>