SAN FRANCISCO - A disability plan insurer abused its discretion in violation of the Employee Retirement Income Security Act through its interpretation of the plan's provision regarding offsets for current income, the Ninth Circuit U.S. Court of Appeals ruled June 18 in an unpublished opinion (Jonathan E. Rivkin, M.D. v. The Union Central Life Insurance Company, No. 11-55975, 9th Cir.; 2013 U.S. App. LEXIS 12377).