Justia ERISA Opinion SummariesArticles Posted in Education Law
Cent St, SE & SW Areas Health & Welfare Fund v. First Agency, Inc.
Central States, an employee benefit plan governed by the Employee Retirement Income Security Act, provides health insurance for Teamsters and their families. Guarantee Trust provides sports injury insurance for student athletes. Each of 13 high school and college athletes, all children of Teamsters, holds general health insurance from Central and sports injury insurance from Guarantee. Each suffered an injury while playing sports (most often football) between 2006 and 2009, and sought coverage from both companies. Each time Guarantee refused to pay the athlete’s medical expenses, and each time Central paid the bill under protest. The district court entered a declaratory judgment under ERISA, 29 U.S.C. 1132(a)(3)(B), that, when coverage of student athletes overlap, Guarantee must pay, and ordered Guarantee to reimburse Central for the payouts to the 13 students. The Sixth Circuit, affirmed in part characterizing the case as a “you first” paradox, or ‘gastonette.” An ERISA plan may coordinate benefits with another policy, but may not redefine the coverage of another policy. Absent the Central plan, the Guarantee policy would cover the sports injuries at issue without question. An ERISA plan must keep doing what it would do in another plan’s absence. That amounts to coordinating benefits, not redefining coverage. View "Cent St, SE & SW Areas Health & Welfare Fund v. First Agency, Inc." on Justia Law
Pettaway v. Teachers Ins. and Annuity, et al.
After injuring her back in a car accident, plaintiff filed for and received long-term disability benefits from the insurance plan sponsored by her employer. Plaintiff brought suit pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), 42 U.S. C. 29 U.S.C. 1001 et seq., against her employer and the administrators and underwriters of her employer-sponsored long-term benefit disability insurance policy after the claims administrator of that plan determined that she no longer qualified for benefits. At issue was whether the district court properly granted defendants' motion for summary judgment, finding no violation of law. The court held that because defendants acted reasonably, the court concluded that defendants' termination of plaintiff's benefits complied with federal law. The court found none of plaintiff's procedural claims persuasive and held that the district court did not err when it held that defendants did not violate plaintiff's right to a full and fair review of her adverse eligibility determination. The court also rejected plaintiff's argument that the district court violated local rule 7(h) where plaintiff failed to make this argument before the district court. Accordingly, the court affirmed the judgment of the district court. View "Pettaway v. Teachers Ins. and Annuity, et al." on Justia Law