Rhea v. Alan Ritchey, Inc. Welfare Benefit Plan

After plaintiff settled a medical malpractice claim, the employee benefit plan organized under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., sought reimbursement. The Fifth Circuit held that when the plan paid for plaintiff's medical expenses, its summary plan description (SPD) can function as both an SPD and a written instrument; the SPD sufficiently complied with section 1102(b) by giving sufficient information regarding how the plan is funded or how it can be amended; when an SPD is a plan's only plausible written instrument, courts assume that the SPD is the written instrument; an SPD that defers to a non-existent plan document can be enforced as the plan's governing text; and the equities favor defendants in this case. The court also concluded that there was no abuse of discretion in issuing the award of attorneys' fees and costs. Accordingly, the court affirmed the district court's grant of summary judgment and fees and costs to defendants. View "Rhea v. Alan Ritchey, Inc. Welfare Benefit Plan" on Justia Law