Justia ERISA Opinion Summaries
Doe v. Harvard Pilgrim Health Care, Inc.
In this ERISA action, the First Circuit affirmed the rulings of the district court entering judgment for Defendants on remand and refusing to award Plaintiff attorneys' fees for her success on a prior appeal, holding that there was no clear error on the part of the district court.Plaintiff spent several months at a residential mental health treatment center. Defendants covered certain costs of Plaintiff's treatment but denied coverage for a four-month period on the grounds that Plaintiff could have stepped down to a lower level of treatment during that period. Plaintiff brought suit seeking de novo review of her claim for coverage of the four-month period under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001-1461. The district court entered summary judgment for Defendants. The First Circuit vacated the judgment and remanded so the district court could consider additional evidence. On remand, the district court again granted summary judgment for Defendants. The First Circuit affirmed, holding (1) it was not clear error for the district court to conclude that, at the beginning of the four-month period, Plaintiff's continued stay at the residential facility was not medically necessary; and (2) there was no clear error in the district court's decision not to award attorney's fees. View "Doe v. Harvard Pilgrim Health Care, Inc." on Justia Law
American Federation of Musicians and Employers’ Pension Fund v. Neshoma Orchestra and Singers, Inc.
The Fund brought this action to collect $1.1 million in withdrawal liability under the Employee Retirement Income Security Act (ERISA). At issue was whether arbitration was properly initiated by Neshoma in response to the suit and whether Neshoma's third-party claim against its union was preempted by the National Labor Relations Act (NLRA).The Second Circuit held that the parties were bound by the Fund rules, which required Neshoma to initiate arbitration with the AAA by filing a formal request before the statutory deadline, and Neshoma failed to do so. The court also held that the district court did not err in dismissing Neshoma's third-party complaint against the Union on the pleadings as preempted by the NLRA. Accordingly, the court affirmed the judgment. View "American Federation of Musicians and Employers' Pension Fund v. Neshoma Orchestra and Singers, Inc." on Justia Law
Black v. Pension Benefit Guaranty Corp.
Title IV of the Employee Retirement Income Security Act of 1974 (ERISA) creates an insurance program to protect employees’ pension benefits. The Pension Benefit Guaranty Corporation (PBGC)—a wholly-owned corporation of the U.S. government—is charged with administering the pension-insurance program. PBGC terminated the “Salaried Plan,” a defined-benefit plan sponsored by Delphi by an agreement between PBGC and Delphi pursuant to 29 U.S.C. 1342(c). Delphi had filed a voluntary Chapter 11 bankruptcy petition and had stopped making contributions to the plan. The district court rejected challenges by retirees affected by the termination.The Sixth Circuit affirmed. Subsection 1342(c) permits termination of distressed pension plans by agreement between PBGC and the plan administrator without court adjudication. Rejecting a due process argument, the court stated that the retirees have not demonstrated that they have a property interest in the full amount of their vested, but unfunded, pension benefits. PBGC’s decision to terminate the Salaried Plan was not arbitrary and capricious. View "Black v. Pension Benefit Guaranty Corp." on Justia Law
McKennan v. Meadowvale Dairy Employee Benefit Plan
The Eighth Circuit reversed the district court's order requiring the Meadowvale Dairy Employee Benefit Plan to pay benefits and attorney's fees to Avera under the Employee Retirement Income Security Act of 1974 (ERISA). Avera alleged that the benefits at issue were due to a former employee of Meadowvale who received care at a hospital operated by Avera.The court held that, although the beneficiary assigned any and all causes of action to Avera, he never had a cause of action against the Plan. Therefore, Avera may not proceed against the Plan under ERISA as an assignee of a beneficiary or otherwise. In this case, after Meadowvale rescinded the beneficiary's coverage under the Plan, neither the employee nor an authorized representative of his exhausted internal remedies to challenge the decision. View "McKennan v. Meadowvale Dairy Employee Benefit Plan" on Justia Law
Bator v. District Council 4, Graphic Communications Conference
Bell employees participated in a benefit plan, completely funded by contributions from the members of about 69 unions. The plan is administered by a Board of Trustees, governed by Trust Indenture documents that provide that plan members must contribute a fixed amount unless a member’s union has set a different contribution amount. In 2008, Bell’s union voted to increase its members’ contributions from 6% to 8% of their weekly wages. In 2014, the Trustees revealed that the plan’s financial health was deteriorating. Bell employees unsuccessfully petitioned the union to reduce their compelled-contribution rate. In 2016, Bell's collective-bargaining contract expired. During negotiations, the employees again unsuccessfully requested that the union reduce their required contribution rate. Other members of the union, working for a different employer, were either contributing at lower rates or not contributing; they were originally part of a different union that did not participate in the plan. Contract re-negotiations were unsuccessful. The employees lost certain benefits that are available only to active contributors to the plan.The Seventh Circuit affirmed the dismissal of a suit under 29 U.S.C. 1104(a)(1)(D). The Trustees’ action, interpretation of the Trust Indenture, was not a breach of fiduciary duty. The Indenture can be reasonably interpreted as permitting different segments within a union to contribute to the plan at different levels. Even if the Union controlled the amount of revenue coming into the plan, it did not act as fiduciary but as a settlor. View "Bator v. District Council 4, Graphic Communications Conference" on Justia Law
Guenther v. Lockheed Martin Corp.
The Ninth Circuit affirmed the district court's order granting summary judgment in favor of defendants in an action under the Employee Retirement Income Security Act (ERISA), alleging that a fiduciary breached its duty to make accurate representations to a beneficiary.The panel first held that defendants did not waive their statute of limitations affirmative defense. The panel applied Intel Corp. Inv. Policy Committee v. Sulyma, 140 S. Ct. 768 (2020), which held that "actual knowledge" requires more than merely a possible inference from ambiguous circumstances, but rather knowledge that is actual. The panel held that the record establishes that the beneficiary had actual knowledge of the alleged breach and failed to bring suit within the three-year statute of limitations prescribed under ERISA. In this case, the district court correctly determined that the beneficiary had actual knowledge of the alleged misrepresentation when he received a letter from defendants regarding the bridging of service under the retirement plan. Therefore, the beneficiary's claim is time-barred. Furthermore, there is no exception for fraudulent concealment that triggers the six-year statute of limitations here. Finally, the panel held that the district court did not abuse its discretion in denying the beneficiary's post-judgment motion for reconsideration. View "Guenther v. Lockheed Martin Corp." on Justia Law
McIntyre v. Reliance Standard Life Insurance Co.
The Eighth Circuit vacated the district court's grant of summary judgment in favor of the plan beneficiary in an action arising under the Employee Retirement Income Security Act (ERISA). The court held that the district court erred in reviewing Reliance's denial of long-term disability benefits de novo rather than for an abuse of discretion. The court explained that the administrator's decisional delay on appeal does not in and of itself trigger de novo review. Rather, under circuit law, de novo review is not triggered in this context unless the administrator wholly fails "to act on an appeal" and that failure "raises serious doubts about the result reached by the plan administrator" in its initial denial. The court remanded for the district court to review Reliance's benefits decision for an abuse of discretion. View "McIntyre v. Reliance Standard Life Insurance Co." on Justia Law
Hill v. Employee Benefits Administrative Committee of Mueller Group LLC
Plaintiff and 22 other employees filed suit under the Employee Retirement Income Security Act (ERISA), challenging the plan administrator's denial of Special Early Retirement (SER) benefits. Plaintiffs claim that they are entitled to SER benefits because the sale of the parent company's interests to another company effected either a layoff or a permanent plant shutdown. Before and after the sale, the factory remained continuously operational and the employees remained employed in their same jobs.The Eleventh Circuit affirmed the district court's denial of the ERISA benefits because plaintiffs were neither laid off nor terminated by a permanent plant shutdown and thus they were not entitled to SER benefits under the language of the plan. The court also held that plaintiffs cannot make out a claim for equitable relief because their alternative theory arises form the same factual circumstances as their first. View "Hill v. Employee Benefits Administrative Committee of Mueller Group LLC" on Justia Law
Castillo v. Metropolitan Life Insurance Co.
29 U.S.C. 1132(a)(3) does not authorize an award of attorney's fees incurred during the administrative phase of the Employee Retirement Income Security Act (ERISA) claims process. The Ninth Circuit affirmed the district court's dismissal of an ERISA action brought by plaintiff against MetLife. The district court granted MetLife's motion to dismiss the complaint, agreeing with MetLife that attorney's fees awards are not other appropriate equitable relief under section 1132(a)(3).In Cann v. Carpenters' Pension Trust Fund for Northern California, 989 F.3d 313 (9th Cir. 1993), the panel held that attorney's fees incurred in administrative proceedings are not recoverable under section 1132(g), ERISA's express fee-shifting provision. The panel was obligated to read section 1132(a)(3) in conjunction with section 1132(g). Under the expressio unius canon, section 1132(g)'s silence as to fees incurred in an administrative proceeding gives rise to the inference that section 1132(a)(3) does not authorize such fees. View "Castillo v. Metropolitan Life Insurance Co." on Justia Law
Quatrone v. Gannett Company, Inc.
Plaintiffs, participants in the Gannett Co. 401(k) Savings Plan, filed suit alleging that defendants breached their fiduciary duties of prudence and diversification under the Employee Retirement Income Security Act (ERISA). Plaintiffs contend that defendants ignored an imprudent single-stock fund in the Plan for several years, resulting in millions of dollars in losses.The Fourth Circuit vacated the district court's dismissal of plaintiff's complaint for failure to state a claim, holding that plaintiffs plausibly alleged that a fiduciary breached a duty, causing a loss to the employee benefit plan. In this case, plaintiffs alleged that defendants breached their duty of prudence by allegedly failing to monitor the continuing prudence of holding a single-stock fund; because defendants did not monitor the merits of the fund, they did not uncover that it was an imprudent fund; defendants' failure to discover the imprudence led to the failure to divest the fund; and, when the price of the stock in the fund went down, the Plan suffered a loss. The court remanded for further proceedings. View "Quatrone v. Gannett Company, Inc." on Justia Law