Justia ERISA Opinion Summaries

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Plaintiff filed a class action against Travelport and the Galileo & Worldspan U.S. Legacy Pension Plan under the Employee Retirement Income Security Act of 1974, alleging claims for improperly withheld pension benefits, document-disclosure penalties, and breach of fiduciary duties. The district court dismissed all claims. With respect to plaintiff's claim for benefits, the Eleventh Circuit reversed and remanded for the district court to review her claim anew after Travelport has certified and submitted the complete and accurate administrative record. The court reversed the district court's award of attorney's fees, but otherwise affirmed the district court's judgment. View "Williamson v. Travelport, LP" on Justia Law

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Plaintiff filed suit against Mercy Health, alleging that Mercy's plan management disregards requirements under the Employee Retirement Income Security Act. Mercy asserted that it does not have to comply with ERISA's requirements because the plan falls under ERISA's church-plan exemption pursuant to 29 U.S.C. 1003(b)(2). The Eighth Circuit held that whether a plan is an ERISA plan is an element of the plaintiff's case and not a jurisdictional inquiry. Therefore, the district court erred in dismissing the case for lack of jurisdiction. The court remanded to the district court to determine whether the deprivation of ERISA protections confers Article III standing, and if so, whether the church-plan exemption violates the Establishment Clause. If there is Article III standing, the state law claims should be reinstated pursuant to the court's supplemental jurisdiction. View "Sanzone v. Mercy Health" on Justia Law

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Under the Retirement Plan, participating Northwestern University employees can contribute a portion of their salary to their account and Northwestern makes a matching contribution. Employees participating in the Voluntary Savings Plan also contribute a portion of their salary, but Northwestern does not make a matching contribution. Both plans allow participants to choose the investments for their accounts from options assembled by the plans’ fiduciaries. Northwestern is the administrator and designated fiduciary of both plans. The plaintiffs sued Northwestern under the Employee Retirement Income Security Act, 29 U.S.C. 1001 (ERISA). The Seventh Circuit affirmed the dismissal of the amended complaint and rejection of the plaintiffs’ demand for a jury trial. Under the plans, no participant was required to invest in any particular product. Any participant could avoid the alleged problems with certain products--record-keeping fees and underperformance. Northwestern provided a wide range of investment options and provided prudent explanations for the challenged fiduciary decisions involving alleged losses. There was no ERISA violation with Northwestern’s record-keeping arrangement; the plaintiffs identified no alternative recordkeeper that would have accepted any fee lower than what was paid nor have they explained how a hypothetical lower-cost recordkeeper would perform at the level necessary to serve the best interests of the plans. View "Divane v. Northwestern University" on Justia Law

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Plaintiffs filed a putative class action against former trustees of the Lifetouch Plan, the Board, and Lifetouch, alleging claims under the Employee Retirement Income Security Act (ERISA). The Eighth Circuit affirmed the district court's dismissal of the amended complaint for failure to state a claim. The court held that, because plaintiffs failed to plead a plausible breach of the duty of prudence by the trustee defendants, the district court properly dismissed their duty to monitor claims against the Board and Lifetouch because those claims cannot survive without a sufficiently pled theory of an underlying breach. View "Vigeant v. Meek" on Justia Law

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Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), alleging that Blue Cross abused its discretion by partially denying their claim for air-ambulance benefits under an employee health plan. The district court granted summary judgment in part to Blue Cross and in part to plaintiffs. The Eighth Circuit held that the wrongful denial of plan benefits breaches the parties' contract and deprives the participant of the benefit of their bargain. Therefore, this constitutes an injury to the participant—even if the benefits are assigned to a third party. In this case, plaintiffs satisfied the injury-in-fact component of constitutional standing. The court also held that plaintiffs had statutory standing, because they have alleged a colorable claim that Blue Cross unreasonably prevented the "Allowed Charge" for "Ambulance Services" and denied their claim for benefits based on that interpretation. On the merits, the court held that Blue Cross did not abuse its discretion by partially denying plaintiffs' claim. The court wrote that the plan gave Blue Cross broad discretion to determine the "Allowed Charge" for air-ambulance services, and Blue Cross has adopted a consistent interpretation, tied to an external benchmark, which is compatible with both the plan's language and its purpose. Finally, the court held that Blue Cross did not abuse its discretion in interpreting the "medical supply" fee language. View "Mitchell v. Blue Cross Blue Shield of North Dakota" on Justia Law

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The Fifth Circuit affirmed the district court's adverse judgment against plaintiffs on Employee Retirement Income Security Act (ERISA) claims assigned by Cigna-insured patients. The court held that the law of the case did not require the district court on remand to determine the legal correctness of Cigna's policy interpretation, and under Connecticut General Life Insurance Co. v. Humble Surgical Hospital, L.L.C., 878 F.3d 478, 485 (5th Cir. 2017), a court need not reach legal correctness if the insurer's determination was not an abuse of discretion. Furthermore, Humble moots consideration of the conflicts and inferences of bad faith that plaintiffs assert against Cigna. In this case, the district court correctly applied this court's previous decision in the instant controversy as well as Humble, and thus plaintiffs' exhaustion argument was moot. Plaintiffs' procedural challenge to Cigna's review failed for lack of substantiating evidence, which left the damages issue moot. Finally, plaintiffs failed to establish any right to attorney's fees. View "North Cypress Medical Center Operating Co. v. Cigna Healthcare" on Justia Law

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The Employee Retirement Income Security Act (ERISA) requires plaintiffs with “actual knowledge” of an alleged fiduciary breach to file suit within three years of gaining that knowledge, 29 U.S.C. 1113(2), rather than within the six-year period that would otherwise apply. Sulyma worked at Intel, 2010-2012, and participated in retirement plans. In 2015, he sued plan administrators, alleging that they had managed the plans imprudently. Although Sulyma had visited the website that hosted disclosures of investment decisions, he testified that he did not remember reviewing the relevant disclosures and that he had been unaware of the allegedly imprudent investments while working at Intel. Reversing summary judgment, the Ninth Circuit held that Sulyma's testimony created a dispute as to when he gained “actual knowledge.” A unanimous Supreme Court affirmed. A plaintiff does not necessarily have “actual knowledge” of the information contained in disclosures that he receives but does not read or cannot recall reading. To meet the “actual knowledge” requirement, the plaintiff must, in fact, have become aware of that information. The law sometimes imputes “constructive” knowledge to a person who fails to learn something that a reasonably diligent person would have learned but section 1113(2)'s addition of “actual” signals that the plaintiff’s knowledge must be more than hypothetical. While section 1113(2)'s plain meaning substantially diminishes the protection of ERISA fiduciaries, Congress must be the one to make changes. The Court noted the “usual ways” to prove actual knowledge. View "Intel Corp. Investment Policy Committee v. Sulyma" on Justia Law

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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

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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

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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