Justia ERISA Opinion Summaries
Arruda v. Zurich American Insurance Co.
In this insurance dispute, the First Circuit directed entry of summary judgment for Zurich American Insurance Company, holding that Zurich's decision to deny the insured's claim was supported by substantial evidence. Denise Arruda filed a claim for death benefits following the death of her husband, Joseph Arruda, in a car accident. Zurich denied the claim, concluding that Joseph's death was not within the coverage clause of the policy because the death was not independent of all other causes and that it was caused or contributed to by his pre-existing health conditions. Denise brought this action under 29 U.S.C. 1132(a)(1)(B) alleging that Zurich violated ERISA by denying the insurance benefits. The district court entered summary judgment in favor of Denise, concluding that substantial evidence did not support Zurich's decision. The First Circuit reversed, holding that Zurich's conclusion that Joseph's death was caused or contributed to by pre-existing medical conditions was not arbitrary or capricious and was supported by substantial evidence. View "Arruda v. Zurich American Insurance Co." on Justia Law
Johnson v. Charps Welding & Fabricating, Inc.
Trustees of three employee benefit funds filed suit against Charps and others, alleging that defendants breached collective bargaining agreements by not contributing to the employee benefit funds for work performed by the affiliates, in violation of the Employee Retirement Income Security Act (ERISA). The district court granted summary judgment to defendants, awarding them attorney's fees and costs. The Eighth Circuit held that defendants did not owe contributions for the affiliates' work where the trustees have not shown a genuine issue that the defendant companies formed a relationship of alter ego, joint venture, or joint enterprise. Furthermore, the collective bargaining agreements did not require defendants to contribute for the work of Charps' affiliates. The court also held that the trustees did not meet their burden in opposing summary judgment on their claim that the district court failed to address Charps' liability for contributions based on its own employees' work, and the district court did not abuse its discretion in denying, as duplicative, the trustees' motion to compel production of the spreadsheets. Accordingly, the court affirmed the judgment in 18-3007, but reversed and remanded in 19-1206. On remand, the district court should award costs that are taxable under 28 U.S.C. 1821 and 1920. In regard to the nontaxable costs, the district court may determine whether they may be awarded as attorney's fees. View "Johnson v. Charps Welding & Fabricating, Inc." on Justia Law
Dorris v. Unum Life Insurance Co. of America
Dorris, a company president, had Unum long-term disability insurance. Her endometriosis became disabling; Unum started paying her benefits in 2002. Later, Dorris was diagnosed with Lyme disease. By 2007, the Social Security Administration granted her disability benefits. To maintain Unum benefits after two years, an employee had to prove that she “cannot perform each of the material duties of any gainful occupation for which [she is] reasonably fitted” or that she is “[p]erforming at least one of the material duties" of any occupation and “[c]urrently earning at least 20% less" due to the disability. In 2015, Dorris told Unum that she was improving and had started golfing and volunteering. Dorris’s Lyme disease specialist indicated that Dorris still had major symptoms and could not work. Unum’s consulting physicians found no evidence of limitations that would preclude sedentary work nor of an active Lyme infection. Unum ended her benefits. In her Employee Retirement Income Security Act (29 U.S.C. 1132(a)(1)(B)) lawsuit, Dorris was denied permission to depose witnesses to clarify the administrative record. Dorris never sought further discovery; nor objected to the ruling. Unum rested on its physician’s conclusions that Dorris could perform the duties of a president. Dorris asserted, without evidence, that such jobs required “55–70 hours a week,” and focused on how little she did as a volunteer. The court limited its review to the administrative record and found that Dorris could not perform the duties of her regular occupation, but nonetheless ruled in Unum's favor, because Dorris's arguments based on the "20% less" option were conclusory. The Seventh Circuit affirmed. The plaintiff bears the burden of proving that she is entitled to benefits. The court did not abuse its discretion in denying Dorris the opportunity to supplement the record after judgment nor were its factual findings in error. View "Dorris v. Unum Life Insurance Co. of America" on Justia Law
Rozo v. Principal Life Insurance Co.
The Eighth Circuit reversed the district court's grant of summary judgment to Principal in an action brought under the Employee Retirement Income Security Act (ERISA). The court held that Principal is a fiduciary when its sets the Composite Crediting Rate (CCR) for its 401(k) retirement plan. Under the two-part test in Teets v. Great-West Life & Annuity Ins. Co., 921 F.3d 1200 (10th Cir. 2019), the court held that Principal's setting of the CCR does not conform to a specific term of its contract with the employer plan, and the plan sponsors here did not have the unimpeded ability to reject the service provider's action or terminate the relationship. Accordingly, the court reversed and remanded for further proceedings. View "Rozo v. Principal Life Insurance Co." on Justia Law
Martinez v. Sun Life Assurance Co. of Canada
The First Circuit affirmed the judgment of the district court in favor of Sun Life Assurance Company of Canada finding that Sun Life properly permitted an offset of Appellant's benefits under tis employer-sponsored long-term disability insurance policy (the Plan) by the amount of Appellant's service-connection disability compensation (Veterans' Benefits), holding that the district court did not err. Specifically, the First Circuit held (1) Appellant's Veterans' Benefits fell squarely within the definition of "Compulsory Benefit Act or Law"; (2) that the district court did not err by concluding as a matter of law that Veterans' Benefits unambiguously qualify as a form of "Other Income Benefit" covered by the Plan's offset provision; and (3) the district court did not err by rejecting as a matter of law Appellant's assertion that Sun Life's offset determination was motivated, at least in part, by Appellant's military service in violation of the Uniformed Services Employment and Reemployment Rights Act. View "Martinez v. Sun Life Assurance Co. of Canada" on Justia Law
Retirement Plans Committee of IBM v. Jander
In 2014, the Supreme Court held that a claim for breach of the duty of prudence imposed on plan fiduciaries by the Employee Retirement Income Security Act (ERISA) on the basis of inside information, must plausibly allege an alternative action that would have been consistent with securities laws and that a prudent fiduciary would not have viewed as more likely to harm the fund than to help it. The ERISA duty of prudence does not require a fiduciary to break the law and cannot require the fiduciary of an Employee Stock Ownership Plan (ESOP) “to perform an action—such as divesting the fund’s holdings of the employer’s stock on the basis of inside information—that would violate the securities laws.” In 2018, the Second Circuit reinstated a claim for breach of fiduciary duty under ERISA brought by participants in IBM’s 401(k) plan who suffered losses from their investment in IBM stock. The Supreme Court vacated and remanded, characterizing the question as what it takes to plausibly allege an alternative action “that a prudent fiduciary in the same circumstances would not have viewed as more likely to harm the fund than to help it” and whether that pleading standard can be satisfied by generalized allegations that the harm of an inevitable disclosure of an alleged fraud generally increases over time.” The Court concluded that the Second Circuit did not address those questions and noted that the views of the Securities and Exchange Commission might “well be relevant” to discerning the content of ERISA’s duty of prudence in this context. View "Retirement Plans Committee of IBM v. Jander" on Justia Law
The National Retirement Fund v. Metz Culinary Management, Inc.
Metz appealed the district court's judgment vacating an arbitration award that held that interest rate assumptions for purposes of withdrawal from a multiemployer pension plan liability are those in effect on the last day of the year preceding the employer's withdrawal. The district court held, however, that section 4213 of the Employee Retirement Income Security Act (ERISA) does not require actuaries to calculate withdrawal liability based on interest rate assumptions used prior to an employer's withdrawal from a plan, and that interest rate assumptions must be affirmatively reached and may not roll over automatically from the preceding plan year. The Second Circuit vacated the district court's judgment, holding that interest rate assumptions for withdrawal liability purposes must be determined as of the last day of the year preceding the employer's withdrawal from a multiemployer pension plan. Furthermore, absent any change to the previous plan year's assumption made by the Measurement Date, the interest rate assumption in place from the previous plan year will roll over automatically. Accordingly, the court remanded with directions to enter judgment for Metz and to remand any remaining issues to the arbitrator. View "The National Retirement Fund v. Metz Culinary Management, Inc." on Justia Law
Laurent v. PricewaterhouseCoopers LLP
The Second Circuit vacated the district court's dismissal of plaintiffs' claims alleging that the terms of their employee retirement benefits plan violated the Employment Retirement Income Security Act (ERISA). In a prior appeal, the court affirmed the district court's holding that the plan violated the statue and remanded to the district court for consideration of the appropriate relief. On remand, defendants moved on the pleadings under Federal Rule of Civil Procedure 12(c), contending that the relief requested by plaintiffs was unavailable as a matter of law. The district court agreed and granted defendants' motion. The court held that section 502(a)(3) authorizes district courts to grant equitable relief ‐‐ including reformation ‐‐ to remedy violations of subsection I of ERISA, even in the absence of mistake, fraud, or other conduct traditionally considered to be inequitable. Furthermore, the district court is authorized to grant plaintiffs' proposed remedy of enforcement of the reformed plan under section 502(a)(1)(B). Accordingly, the court remanded for further proceedings. View "Laurent v. PricewaterhouseCoopers LLP" on Justia Law
Miller v. Hartford Life & Accident Insurance Co.
The Eighth Circuit affirmed the district court's dismissal of plaintiff's complaint against Hartford Life in an Employee Retirement Income Security Act (ERISA) action. The court held that the district court did not err by dismissing the complaint with prejudice, because substantial evidence supported Hartford Life's decision to terminate benefits based on exhaustion of mental illness benefits and the lack of a disabling physical condition. In this case, Hartford Life found no disabling physical condition or mental illness based on the medical evidence and the opinions of treating, examining, and reviewing physicians. View "Miller v. Hartford Life & Accident Insurance Co." on Justia Law
Jones v. Aetna Life Insurance Co.
When Aetna terminated plaintiff's disability benefits, she filed an Employee Retirement Income Security Act suit. The Eighth Circuit affirmed the district court's judgment on remand, holding that the district court did not err by determining that plaintiff failed to administratively exhaust her breach of fiduciary duty claim. View "Jones v. Aetna Life Insurance Co." on Justia Law