Justia ERISA Opinion Summaries

Plaintiff, the executrix of her husband's estate, along with her husband's former business, Federal City, filed suit against Life Investors for conversion and tortious interference with a contract. On appeal, plaintiffs challenged the district court's dismissal of the complaint. The court concluded that this action is not barred by claim preclusion because the claims brought are not based upon the same cause of action as the prior suit. In this case, plaintiffs allege claims for conversion and tortious interference with contract against Life Investors because Life Investors removed over $400,000 from certain accounts to cover expenses above the alleged debt plaintiffs owed Life Investors. Life Investors removed these funds after the decision in the Maryland district court. The Maryland court never determined that plaintiffs lacked any interest in the assets in the accounts. Instead, it decided that plaintiffs were time-barred from bringing claims from a 2000 request for withdrawal of the assets and that the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., claims were either time-barred or failed to allege a violation of ERISA law. Similarly, the claim is not barred by issue preclusion. Accordingly, the court reversed and remanded. View "Corrado v. Life Investors Ins. Co." on Justia Law

Life Investors filed suit against defendants, alleging breach of a settlement agreement that required defendants to repay advances of monies defendants received from Life Investors. On appeal, defendants challenged the district court's grant of summary judgment to Life Investors. The court affirmed, concluding that defendants' laches defense failed because they cannot show unreasonable delay on the part of Life Investors in bringing this suit nor can defendants show that they were prejudiced; even if the alleged inconsistencies were material, defendants chose not to investigate further and thus the determination that they ratified the Settlement Agreement was correct; the district court correctly granted summary judgment on the question of ratification of the Settlement Agreement after certifying that question to the Iowa Supreme Court and receiving its answer; and defendants' attempt to argue an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., violation as a defense in this action is barred as a matter of issue preclusion. View "Life Investors Ins. Co. v. Federal City Region" on Justia Law

During his employment with a subsidiary of Santander Holdings, Stevens received treatment for ankylosing spondylitis, a chronic inflammatory disease, and participated in a short-term disability plan (STD) and a long-term disability plan (LTD). When Stevens’ condition worsened, Liberty Mutual, the administrator of Santander’s plans, initially awarded STD benefits to Stevens, then determined that Stevens no longer suffered from a qualifying disability and terminated his benefits. Stevens sued under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001. The district court found that Liberty Mutual’s decision to terminate Stevens’s STD benefits was arbitrary and capricious and remanded with instructions to reinstate Stevens’s STD benefit payments retroactively and to determine his eligibility for LTD benefit payments. The Third Circuit dismissed an appeal for lack of jurisdiction, finding that the remand order to the plan administrator was not a “final decision” appealable pursuant to 28 U.S.C. 1291 at that time. The district court retained jurisdiction over the case and the order is not yet appealable. View "Stevens v. Santander Holdings USA Inc." on Justia Law

Minor O.D. filed a petition for approval of a settlement her parents had negotiated with car insurance companies for injuries she had suffered in a car accident. On the day of the hearing, O.D.'s health insurance coverage provider Ashley Healthcare Plan, which had a subrogation lien against the proceeds of O.D.'s claim, removed the case to federal court, arguing that Mississippi Code Section 93-13-59 (which requires chancery court approval of settlement claims) was preempted by the federal Employment Retirement Income Security Act of 1974 ("ERISA"). The federal district court held that ERISA did not preempt the state law and remanded the case to the chancery court without awarding attorney's fees to O.D. On motion from O.D.'s parents, the Pontotoc County Chancery Court awarded O.D. attorney's fees, holding that Ashley Healthcare Plan's removal to federal court was contrary to clearly established law and that it was done for the purpose of delaying litigation. Ashley Healthcare Plan appealed the grant of attorney fees. The Mississippi Supreme Court affirmed. Although O.D. could have sought recovery of attorney's fees under Rule 54 of the Federal Rules of Civil Procedure, frivolous removals to federal court were also subject to the Mississippi Litigation Accountability Act. Furthermore, Ashley Healthcare Plan's removal to federal court was contrary to two decades of case law which uniformly held that Mississippi's law requiring chancery court approval of minors' settlements was not preempted by ERISA and that Ashley Healthcare Plan was seeking a remedy in federal court that was unavailable to it under the ERISA Civil Enforcement Clause. View "In the Matter of the Guardianship of O. D." on Justia Law

National Retirement Fund sought to hold Mezz Lender and Oaktree Capital responsible for multiemployer pension fund withdrawal liability under the Multiemployer Pension Plan Amendments Act of 1980, 29 U.S.C. 1381. Oaktree, through Mezz Lender, provided financing for the acquisition of a hotel by Chicago H&S. When H&S defaulted, it was taken into bankruptcy and the hotel was liquidated. NRF contends that the sale of the hotel triggered withdrawal liability on the part of H&S and any other “trade or business” under common control with it, including bot Oaktree and Mezz Lender. Oaktree and Mezz Lender, argued that the claim of withdrawal liability was barred by the bankruptcy reorganization plan pursuant to which the hotel was sold. On motions for summary judgment, the court stated that having decided that Oaktree and Mezz were not jointly and severally liable for H&S’s withdrawal liability, "the Court need not address the parties’ arguments as to [the Oaktree parties’] motion" concerning the bankruptcy. The Seventh Circuit vacated. The court decided in the absence of a cross-motion for summary judgment on the issue that it found to be dispositive, and without first giving the unsuccessful movant notice that it was entertaining the possibility of entering summary judgment against it or the opportunity to respond. View "Hotel 71 Mezz Lender LLC v. National Retirement Fund" on Justia Law

Plaintiff filed a class action suit against his former employer, Harman, under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., alleging that Harman breached its fiduciary duties by making false and misleading statements to investment firms. On appeal, plaintiff challenged the district court's conversion of defendants' motion to dismiss under Federal Rule of Civil Procedure 12(b)(6)(d) and grant of summary judgment to defendants without giving plaintiff a reasonable opportunity to present evidence. The court did not reach the merits of the appeal, concluding that if the district court violated Rule 12(d), the error would be harmless in this case where discovery would be futile. Accordingly, the court affirmed the judgment. View "Russell v. Harman Int'l Indus." on Justia Law

Smith was an employee CGC, which offered some employees, including Smith, enhanced compensation if they would remain with CGC through its merger with AEGON. Under the Voluntary Employee Retention and Retirement Program (VERRP) Smith would retire in 2000. Smith elected to receive $1,066.54 under the qualified plan and $1,122.97 under the non-qualified plan, through the “AEGON USA Pension Plan: Election for Distribution and Explanation of Benefits.” An attachment informed Smith that “you will be entitled to receive additional benefits from the [CGC] Retirement Plan.” The two plans subsequently merged. Smith retired and the Plan paid him a lump sum plus $2,189.51 per month. In 2007, AEGON amended the Plan to add a “Restriction on Venue. A participant or Beneficiary shall only bring an action in connection with the Plan in Federal District Court in Cedar Rapids, Iowa.” In 2011, the Plan told Smith that it had overpaid him by $1,122.97 per month for 11 years and eliminated Smith’s entire monthly payment to obtain recoupment. Smith exhausted administrative remedies then filed suit against CGC in state court, asserting breach of contract, wage and hour statutory violations, estoppel, and breach of the duty of good faith and fair dealing. CGC removed the action to federal court, which dismissed, finding that that the VERRP was regulated by ERISA, that Smith was suing to recover benefits under this ERISA plan, and that only the Pension Committee, not CGC, was a proper defendant. The Sixth Circuit affirmed. Smith filed suit against the AEGON Plan in the U.S. District Court for the Western District of Kentucky. The district court dismissed based on the venue selection clause. The Sixth Circuit affirmed, upholding the venue selection clause as applying to all actions brought by a participant or beneficiary, not just claims for benefits. View "Roger Smith v. Aegon Companies Pension Plan" on Justia Law

After defendant Elem suffered injuries in a car accident, she and her attorney conspired to hide and disburse settlement funds from an employee welfare benefit plan she received after the accident. The parties filed cross motions for summary judgment and the district court granted summary judgment for the employer, as well as awarded attorney's fees and costs to the employer. The court affirmed, concluding that the district court had the authority to sanction defendants for their bad faith. The court also concluded that defendant's claim that the district court misapplied Federal Rule of Civil Procedure 70 was moot and dismissed the appeal. View "AirTran Airways, Inc. v. Elem, et al." on Justia Law

Plaintiff filed suit against her employer, Reliastar, under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., after she was denied long term disability benefits. The district court found that Reliastar's benefits determination was arbitrary and capricious, and remanded to the company to calculate the amount of benefits owed. Reliastar appealed. The court dismissed the appeal for lack of appellate jurisdiction, holding that the remand order is not an immediately appealable final decision under either the traditional principles of finality or the court's precedents governing remands to administrative agencies. View "Mead v. Reliastar Life Ins. Co." on Justia Law

Employers that withdraw from underfunded multiemployer pension plans must pay their share of the shortfall. They can seek recalculation of the plans' assessment within 90 days, 29 U.S.C. 1399(b)(2)(A), and within another 60 days, may invoke a process that the Act calls arbitration, though it is neither contractual nor consensual. Central States Pension Fund concluded that US Foods has withdrawn in part and assessed liability in 2008 and in 2009. US Foods timely requested arbitration of the 2009 assessment, but did not timely seek arbitration of the 2008 assessment. In the Fund’s suit to collect the 2008 assessment, US Foods asked the court to order the arbitrator to calculate the amount due for 2008 and 2009 jointly. The court ruled that US Foods had missed the deadline for arbitral resolution of the 2008 assessment. US Foods appealed, relying on 9 U.S.C.16(a)(1)(B), which authorizes an interlocutory appeal from an order “denying a petition under section 4 of this title to order arbitration to proceed”. The Seventh Circuit dismissed for lack of jurisdiction. An order declining to interfere in the conduct of an arbitration is not an order “denying a petition under section 4 of this title to order arbitration to proceed” under section 16(a)(1)(B). View "Cent. States SE & SW Areas Pension Fund v. US Foods, Inc." on Justia Law