Kilbourn v. Henderson case brief summary

Kilbourn  v. Henderson
 

·         Case Facts: Employer’s health plan administrator overstated coverage avail. to an EE (∏), who incurred substantial medical bills on reliance of that coverage. Insurance co. (∆) refused to pay bills, citing the policy. EE sued ins. co. claiming that employer’s h.p.a. was agent for ins. co. and bound ins. co. by her statements.

 

·         Rule: Employer’s administration of a group insurance plan does not create an agency relationship between the employer and insurance co. 

 

·         Analysis: Employer is acting only for benefit of its EEs & the employer’s own benefit in promoting better relations btwn itself and its EEs.

 

o       Thus ins. co. not bound by employer’s h.p.a’s statements and ins. co. not responsible for the coverage.