9th Circuit upholds dismissal of insurance agent Travis Glenn's lawsuit against Americo Financial, finding his…
Glenn v. Americo Financial Life and Annuity Insurance Company
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9th Circuit upholds dismissal of insurance agent Travis Glenn's lawsuit against Americo Financial, finding his claims lacked standing or sufficient factual support.
Why it matters
A federal appeals court affirmed the dismissal of Travis Glenn's lawsuit against Americo Financial Life and Annuity Insurance Company. Glenn, a pro se plaintiff (meaning he represented himself), brought multiple claims including unlawful termination, breach of contract, and whistleblower violations, but the court found he either lacked standing to sue or failed to allege enough facts to support his claims. The court also found that allowing him to amend his complaint again would be futile, given prior chances to fix the deficiencies.
Who it affects
- Particularly self-represented plaintiffs
- Who must allege concrete injuries
- Specific supporting facts
- Not just vague or speculative harms
What happens next
Current
Decision issued Jul 21, 2026
Unpublished opinion
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- Decision issued Jul 21, 2026Unpublished opinion
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Decision issued
Jul 21, 2026 · Unpublished opinion
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DEEPER READ
Travis Glenn, a former insurance agent, sued Americo Financial Life and Annuity Insurance Company raising several legal claims: that Americo failed to send him tax documents, violated COVID-19 guidelines in a way that caused him financial harm, wrongfully terminated him without 120 days notice, engaged in malicious and unfair business practices, breached a contract, and violated whistleblower protections. The district court dismissed his complaint and denied his motion for a preliminary injunction. Glenn appealed to the Ninth Circuit, representing himself. The appeals court addressed each claim in turn. On the tax document issue, it ruled Glenn lacked legal standing because he only alleged a potential future financial harm, not a concrete, actual or imminent one. Courts require a real injury, not a speculative one, to allow a lawsuit to proceed. On the COVID-19 guidelines claim, the court found Glenn's allegations too vague, noting he did not explain what specific financial losses he suffered or how they connected to Americo's conduct. For the remaining claims, the court found Glenn failed to identify any statutes or legal theories that would entitle him to 120 days notice before termination, an opportunity to appeal his firing, or reimbursement for his client acquisition costs. On the breach of contract claim, he did not allege which contractual duty Americo violated or that he himself fulfilled his obligations under any contract. On the whistleblower claim, he did not allege that he made any complaints before being terminated, which is a basic requirement for such a claim. The court also upheld the denial of leave to amend the complaint a further time, because Glenn had already been given multiple chances to fix the problems and had been notified of the deficiencies. Further amendment was deemed futile. The court also ruled that Glenn waived any challenge to the denial of his preliminary injunction by not mentioning it in his opening brief, and separately noted that because his underlying claims failed, he could not have shown the required likelihood of success on the merits to obtain an injunction. The panel of three judges unanimously affirmed the lower court's decision in all respects. There was no dissent.
CITATION AND RECORD
Record source: CourtListener
NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JUL 21 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT TRAVIS M. GLENN, No. 25-4429 D.C. No. Plaintiff - Appellant, 2:24-cv-00184-TL v. MEMORANDUM* AMERICO FINANCIAL LIFE AND ANNUITY INSURANCE COMPANY, Defendant - Appellee. Appeal from the United States District Court for the Western District of Washington Tana Lin, District Judge, Presiding Submitted July 15, 2026** Before: BERZON, NGUYEN, and OWENS, Circuit Judges. Travis M. Glenn appeals pro se from the district court’s (1) dismissal of his Second Amended Complaint (“SAC”) without leave to amend, and (2) denial of his motion for a preliminary injunction as moot. As the parties are familiar with * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). the facts, we do not recount them here. We have jurisdiction under 28 U.S.C § 1291, and we affirm. 1. The district court properly dismissed Glenn’s claim relating to Americo’s failure to send him tax documents for lack of standing. Glenn alleged that Americo’s failure to send him tax information “has the potential to cause financial harm.” But to confer standing, an injury must be “actual or imminent, not conjectural or hypothetical.” Lujan v. Defs. of Wildlife, 504 U.S. 555, 560 (1992) (internal quotation marks omitted). 2. Glenn fails to state a claim in connection with Americo’s alleged violation of COVID-19 guidelines. To avoid dismissal, a plaintiff must allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). Plaintiffs must allege “more than a sheer possibility that a defendant has acted unlawfully.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citation omitted). Glenn alleged that Americo’s “disregard for COVID-19 guidelines led to the termination of client policies” leading to “financial losses . . . through chargebacks and lost commissions.” But he failed to explain what financial losses he incurred, how the chargebacks worked, and how they were related to Americo’s “disregard” for COVID-19 guidelines. His “[v]ague and conclusory allegations” are not sufficient to avoid dismissal. Litmon v. Harris, 768 F.3d 1237, 1241 (9th Cir. 2014). 2 25-4429 3. The district court properly dismissed Glenn’s claims for unlawful termination, malicious and unfair business practices, breach of contract, and whistleblower violations for failure to state a claim. Glenn fails to cite any statutes under which his termination without 120 days of notice is unlawful. Though he alleges he was terminated without due process or opportunity to appeal, and that he lost his book of business, Glenn fails to cite any applicable statutes or cognizable legal theories demonstrating that he was entitled to notice, opportunity to appeal, or reimbursement for the cost of acquiring his clients. He has therefore failed to state a claim for unlawful termination or malicious and unfair business practices. In addition, Glenn claimed that Americo did not disclose which bank account his commissions were paid into. But he does not allege that this breached any contractual duty, or that he himself performed his obligations under any contract. See, e.g., P.E.L. v. Premera Blue Cross, 540 P.3d 105, 115 (Wash. 2023) (“A breach of contract is actionable only if the contract imposes a duty, the duty is breached, and the breach proximately causes damage to the claimant.”). Finally, while Glenn claims whistleblower violations, he fails to allege that his termination occurred after he made any complaints. 4. The district court did not abuse its discretion in denying leave to amend. Although leave to amend should be given freely, a district court may dismiss without leave to amend where amendment would be “futile.” Cervantes v. 3 25-4429 Countrywide Home Loans, Inc., 656 F.3d 1034, 1041 (9th Cir. 2011). Glenn had opportunities to amend his complaint, and the district court previously provided him with notice of the deficiencies in the complaint. We agree with the district court that further amendment would be “futile.” Id. 5. Because Glenn’s opening brief does not mention the district court’s denial of his motion for a preliminary injunction, any objection to that order is waived. See United States v. Seschillie, 310 F.3d 1208, 1217 (9th Cir. 2002) (“Generally, arguments not raised in the opening brief are deemed waived.”). Furthermore, to obtain a preliminary injunction, a plaintiff must show “a strong likelihood of success on the merits.” Harris v. Bd. of Supervisors, Los Angeles Cnty., 366 F.3d 754, 759 (9th Cir. 2004). As discussed above, Glenn’s complaint was properly dismissed, so he could not show a strong likelihood of success on the merits. The district court properly denied his motion for a preliminary injunction. AFFIRMED. 4 25-4429
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