Justia ERISA Opinion Summaries
DaPron v. Spire Inc. Retirement Plans Committee
Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA) alleging that the Committee wrongfully denied his disability claim under its Employees' Retirement Plan and breached its fiduciary duty by failing to conduct a full and fair review of his medical records when reconsidering his claim. The Eighth Circuit affirmed the district court's judgment in favor of the Plan, holding that the district court properly found that the Committee did not breach its fiduciary duty by failing to review the medical records. The court rejected defendant's claim that the Committee offered different rationales for denying his claim and held that the Committee's denial letters consistently state that the application was denied as untimely because it was not made before or in connection with plaintiff's separation. View "DaPron v. Spire Inc. Retirement Plans Committee" on Justia Law
Katherine P. v. Humana Health Plan, Inc.
The Fifth Circuit denied plaintiff's motion for attorneys' fees under the Employee Retirement Income Security Act. The court held that 29 U.S.C. 1132(g)(1) does not provide unfettered discretion to courts to award fees. The court explained that a fees claimant whose only victory was an interlocutory ruling by the Court of Appeals that his complaint should not have been dismissed for failure to state a claim has not received any relief on the merits. In this case, plaintiff persuaded the court to reverse the district court's summary judgment ruling in favor of Humana. If plaintiff achieves some success on the merits on remand, she may then ask for fees. View "Katherine P. v. Humana Health Plan, Inc." on Justia Law
Crowder v. The Delta Air Line, Inc. Family-Care Savings Plan
After Marvin Crowder died, Fidelity disbursed his plan benefits to his sister as his designated beneficiary. Plaintiff, Marvin's ex-wife, filed suit under the Employee Retirement Income Security Act (ERISA), alleging claims of wrongful denial of benefits and breach of fiduciary duty. The Eleventh Circuit affirmed the district court's dismissal of plaintiff's ERISA claims, holding that the Plan Administrator correctly interpreted the Plan and that, after her divorce, plaintiff had no entitlement to her ex-husband's benefits under the Plan's terms. Because plaintiff was not a "beneficiary" under Section 14.03 of the Plan, she failed to state a plausible claim for wrongly denied benefits. Likewise, plaintiff's claims for breach of fiduciary duty failed because she was not a "beneficiary" under the Plan and defendants owed no ERISA-imposed duties to her. Furthermore, plaintiff also lacked statutory authorization to bring a claim for equitable relief based on defendants' alleged breach of their fiduciary duties. View "Crowder v. The Delta Air Line, Inc. Family-Care Savings Plan" on Justia Law
Jander v. International Business Machines Corp.
The judgment the Second Circuit entered in its initial opinion in this appeal was vacated by the Supreme Court and remanded for reconsideration. The court reinstated the judgment. Plaintiffs, participants in IBM's employee stock option plain filed suit alleging that the plan's fiduciaries breached their duty of prudence under the Employee Retirement Income Security Act (ERISA). The district court granted defendants' motion to dismiss; this court reversed and remanded; and then the Supreme Court granted defendants' petition for certiorari, which presented the question whether a plaintiff can state a duty-of-prudence claim based on generalized allegations that the harm of an inevitable disclosure of an alleged fraud generally increases over time. The Supreme Court also granted the government's motion to participate in oral argument as an amicus curiae in support of neither party, so that it could present the views of the Department of Labor and the Securities and Exchange Commission. After oral argument, the Supreme Court vacated the judgment and remanded, explaining that defendants' and the government's post-certiorari arguments primarily addressed matters that fell beyond the question presented to the Supreme Court, and that had not been raised before this court. The court held that the arguments raised in the supplemental briefs either were previously considered by this court or were not properly raised. To the extent that the arguments were previously considered, the court will not revisit them. To the extent that they were not properly raised, they have been forfeited, and the court declined to entertain them. Accordingly, the court reversed the district court's judgment and remanded for further proceedings. View "Jander v. International Business Machines Corp." on Justia Law
Sullivan-Mestecky v. Verizon Communications, Inc.
Plaintiff filed suit individually and as the beneficiary of the life insurance policy of her mother, Kathleen Sullivan, under the Employee Retirement Income Security Act of 1974 (ERISA), after the denial of Sullivan's life insurance benefits by Verizon and Prudential. The Second Circuit held that the district court did not err in dismissing plaintiff's ERISA section 502(a)(1)(B) claim against both defendants and her section 502(a)(3) claim against Prudential. In this case, the terms limiting Sullivan's death benefits to a percentage of her annual income were accurately stated in the plan and its description, and thus the generous benefits plaintiff seeks never vested under the terms of the plan. However, the court held that the district court erred in dismissing the section 502(a)(3) claim against Verizon, because plaintiff pleaded estoppel as "appropriate equitable relief;" the fiduciary breach is sufficient to support the equitable remedy of surcharge; and reforming the plan to accord with Sullivan's reasonable expectations is an appropriate equitable remedy. Finally, the court rejected Verizon's arguments supporting its denial that it committed a fiduciary breach. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Sullivan-Mestecky v. Verizon Communications, Inc." on Justia Law
Thole v. U. S. Bank N. A.
Plaintiffs are retired participants a defined-benefit retirement plan, which guarantees them a fixed payment each month regardless of the plan’s value or its fiduciaries’ investment decisions. Both have been paid all of their monthly pension benefits so far and are legally entitled to those payments for the rest of their lives. They filed a putative class-action suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001, alleging violations of ERISA’s duties of loyalty and prudence by poorly investing the plan’s assets. They sought the repayment of approximately $750 million to the plan in losses suffered due to mismanagement; injunctive relief, including replacement of the plan’s fiduciaries; and attorney’s fees. The Eighth Circuit and the Supreme Court affirmed the dismissal of the case. Because the plaintiffs have no concrete stake in the lawsuit, they lack Article III standing. Win or lose, they will still receive the exact same monthly benefits they are entitled to receive. Participants in a defined-benefit plan are not similarly situated to the beneficiaries of a private trust or to participants in a defined-contribution plan; they possess no equitable or property interest in the plan. The plaintiffs cannot assert representative standing based on injuries to the plan where they themselves have not “suffered an injury in fact,” or been legally or contractually appointed to represent the plan. The fact that ERISA affords all participants—including defined-benefit plan participants—a cause of action to sue does not satisfy the injury-in-fact requirement. Article III standing requires a concrete injury even in the context of a statutory violation. The Court rejected an argument that meaningful regulation of plan fiduciaries is possible only if they may sue to target perceived fiduciary misconduct; defined-benefit plans are regulated and monitored in multiple ways. View "Thole v. U. S. Bank N. A." on Justia Law
Schweitzer v. Investment Committee of the Phillips 66 Savings Plan
Plaintiffs filed a putative class action against the Investment Committee of the Phillips 66's retirement plan for breach of fiduciary duties under the Employee Retirement Income Security Act (ERISA). The Fifth Circuit rejected plaintiffs' contention that defendants breached their duty to diversify under section 1104(a)(1)(C) of ERISA and their duty of prudence under section 1104(a)(1)(B) by failing to consider reducing their holdings in the ConocoPhillips Funds. Although plaintiffs have plausibly alleged that the ConocoPhillips Funds, by its resulting concentration of investment, became an imprudent investment with the spinoff, the court held that it does not follow that defendants were obligated to force plan participants to divest from the funds. Furthermore, by closing the ConocoPhillips Funds to new investments immediately after the spin-off, defendants also ensured that they were not offering participants an imprudent investment option. Finally, the court rejected plaintiffs' contention that the district court erred in dismissing their claim that defendants failed to comply with their duty "to follow a regular, appropriate, systematic procedure to evaluate the ConocoPhillips Funds as investments in the Plan." Therefore, the court affirmed the district court's grant of defendants' motion to dismiss for failure to state a claim. View "Schweitzer v. Investment Committee of the Phillips 66 Savings Plan" on Justia Law
Davis v. Washington University in St. Louis
Three retirement-plan participants field suit against WashU for breach of its fiduciary duties under the Employee Retirement Income Security Act (ERISA). The district court dismissed the complaint for failure to state a claim. The court held that plaintiffs sufficiently alleged that fees were too high and that WashU should have negotiated a better deal. The court held that a failure of effort or competence is enough to state a claim for breach of the duty of prudence. In this case, two inferences of mismanagement are plausible from the WashU's failure to offer more institutional shares. However, the court held that plaintiffs' claims that WashU had several underperforming investments in the plan for too long was properly dismissed, because the allegations failed to establish a meaningful benchmark for evaluating the challenged options. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Davis v. Washington University in St. Louis" on Justia Law
Katherine P. v. Humana Health Plan, Inc.
This dispute arose from Humana's denial of coverage for plaintiff's hospital stay as not "medically necessary" for treatment of an eating disorder. The Fifth Circuit reviewed Employee Retirement Income Security Act (ERISA) claims such as this one under the framework set forth in Ariana M. v. Humana Health Plan of Texas, Inc., 884 F.3d 246 (5th Cir. 2018) (en banc). The court limited its review of the coverage decision to the administrative record and applied de novo review. The court held that there is a genuine dispute of material fact regarding whether plaintiff met the Mihalik Criteria (ED.PM.4.2 sub-criteria) which precluded summary judgment. Accordingly, the court vacated and remanded for further proceedings. View "Katherine P. v. Humana Health Plan, Inc." on Justia Law
Ellis v. Liberty Life Assurance Co
In 2014, Liberty Life Assurance Company of Boston rejected the claim for long-term disability benefits by plaintiff-appellee Michael Ellis. As part of its employee-benefit plan, Comcast Corporation, for whom Ellis worked in Colorado from 1994 until 2012, had obtained from Liberty in 2005 a Group Disability Income Policy (the Policy). Ellis sought review of Liberty’s denial of benefits in the United States District Court for the District of Colorado under the Employee Retirement Income Security Act of 1974 (ERISA). The district court, reviewing the denial de novo, ruled that Liberty’s denial was not supported by a preponderance of the evidence. Liberty appealed, contending the court should have reviewed its decision under an abuse-of-discretion standard but that it should prevail even under a de novo standard. Ellis defended the district court’s choice of a de novo standard but argued he should prevail under either standard of review. The Tenth Circuit determined a plan administrator’s denial of benefits was ordinarily reviewed by the court de novo; but if the policy gave the administrator discretion to interpret the plan and award benefits, judicial review was for abuse of discretion. The Policy at issue provided that it was governed by the law of Pennsylvania, which was where Comcast was incorporated and has its principal place of business. Among its terms was one that gave Liberty discretion in resolving claims for benefits. A Colorado statute enacted in 2008, however, forbade such grants of discretion in insurance policies. The parties disputed whether the statute applied to the Policy under Colorado law, and whether Colorado law governed. The Tenth Circuit held that in this dispute the law of Pennsylvania was controlling. Liberty’s denial of benefits was therefore properly reviewed for abuse of discretion. Under that standard the denial had to be upheld. View "Ellis v. Liberty Life Assurance Co" on Justia Law