Justia ERISA Opinion SummariesArticles Posted in Employment Law
Ocean City Chamber of Commerce v. Barufaldi
After Respondent resigned as executive director of the Chamber of Commerce, he filed a complaint against the Chamber, alleging violations of the Wage Payment and Collection Law, among other claims. After a jury trial, the court entered judgment against the Chamber. Respondent subsequently filed a motion for an award of attorneys' fees under the Wage Payment and Collection Law. The circuit court denied Respondent's motion on remand after applying a fee-shifting analysis from ERISA cases. The court of special appeals reversed the denial of the motion, holding that the circuit court erred in applying the ERISA factors. The Court of Appeals affirmed, holding that because ERISA and the Wage Payment and Collection Law serve distinct purposes and because their fee-shifting provisions are based on different principles, a trial court should not employ the ERISA fee-shifting test in deciding whether to award attorneys' fees. View "Ocean City Chamber of Commerce v. Barufaldi" on Justia Law
Md. Ins. Comm’r. v. Kaplan
CareFirst, Inc., a nonstock, nonprofit Maryland corporation, is a holding company with two subsidiaries that provides health insurance for millions of Maryland residents. State law confers broad authority on the Maryland Insurance Commissioner to oversee its operation and adherence to its mission. This case arose from the termination of Leon Kaplan, a former executive of CareFirst. CareFirst declined to pay part of the post-termination compensation set forth in Kaplan's employment contract, reasoning that the compensation was not for "work actually performed," as that standard had been interpreted by the Commissioner. The Commissioner affirmed the decision not to pay the benefits, concluding that the payments would violate Md. Code Ann. Ins. 14-139. The Court of Appeals affirmed, holding (1) the Commissioner's determination was not preempted by ERISA; (2) the Commissioner's construction of the insurance code was legally correct; and (3) there was substantial evidence to support the Commissioner's determination in this case.View "Md. Ins. Comm'r. v. Kaplan" on Justia Law
Langston v. Wilson McShane Corp.
At the time of his divorce from Wife, Husband was a participant in a pension fund (Fund). To enforce the interest awarded to her under the decree, Wife needed to serve a domestic relations order (DRO) on the Fund and its administrators (collectively, the Plan) for qualification. Before Wife served any DRO on the Plan, Husband remarried. At the time of Husband's retirement, he made a survivor annuity payable to his current spouse upon his death. Wife eventually served a DRO on the Plan in 2005, but the Plan refused to qualify the DRO. After Husband died, Wife brought a motion to enforce the 2005 DRO. The district court ruled in favor of Wife, concluding (1) surviving spouse benefits do not vest in a plan participant's current spouse at the time of the plan participant's retirement; and (2) therefore, the 2005 DRO served on the Plan was a qualified domestic relations order. The court of appeals reversed. The Supreme Court affirmed, holding (1) under ERISA, surviving spouse benefits vest in a plan participant's current spouse at the time of the plan participant's retirement; and (2) accordingly, the 2005 DRO in this case could not be qualified.View "Langston v. Wilson McShane Corp." on Justia Law
Tex. W. Oaks Hosp., LP v. Williams
At issue in this interlocutory appeal was whether the claims of an employee against his employer, both of whom were health care providers, alleging injuries arising out of inadequate training, supervision, risk-mitigation, and safety in a mental health facility, constituted health care liability claims (HCLCs) under the Texas Medical Liability Act (Act). Employer filed a motion to dismiss on the grounds that Employee's claims constituted HCLCs under the Act and that Employee had not served an expert report on Employer as required under the Act. The trial court denied Employer's motion. The trial court affirmed. The Supreme Court reversed, holding (1) Employee here was properly characterized as a "claimant" under the Act and his allegations against his nonsubscribing Employer were health care and safety claims under the Act's definition of HCLCs, requiring an expert report to maintain his lawsuit; and (2) the Act does not conflict with the Texas Workers' Compensation Act. Remanded.View "Tex. W. Oaks Hosp., LP v. Williams " on Justia Law
TX Dept. of Ins., et al. v. American National Ins. Co., et al.
The parties to the appeal disagreed about whether an employer who self funded a health-benefit plan for its employees was an "insurer" under the Texas Insurance Code, and therefore should be treated as a reinsurer when purchasing stop-loss insurance. The court of appeals concluded that an employer's self-funded plan was clearly an insurer under the Code and that a plan's purchase of stop-loss insurance was also clearly reinsurance beyond the regulatory scope of the Texas Department of Insurance. The court accordingly reversed the trial court's judgment, which held that the agency's regulation of the stop-loss policies at issue as direct insurance. Because the regulatory agency did not clearly err in its regulation of these stop-loss policies, however, the court reversed the court of appeals' judgment and rendered judgment for the agency.View "TX Dept. of Ins., et al. v. American National Ins. Co., et al." on Justia Law
Barnett v. SKF USA, Inc.
The issue before the Supreme Court in this case concerned whether Section 514(a) of the Employee Retirement Income Security Act of 1974 (ERISA), preempted the breach of contract claim asserted by Appellees Lawrence J. Barnett, Christine Cookenback, James M. Defeo, and Madlin Laurent against Appellant SKF USA, Inc. under Pennsylvania law. Appellees were salaried, non-unionized, employees of SKF, working in its Philadelphia plant. The Company also employed hourly unionized employees at the plant. In 1991, SKF announced its decision to shut down the plant and terminate all workers. Over the course of the next year, the effect of the closing on employee retirement rights and benefits became a matter of discussion between Appellees and their supervisors. Appellees' retirement and pension rights were set forth in the an ERISA plan which SKF maintained and administered. Appellees became aware that, as a result of collectively bargaining the effects of plant closing, SKF agreed that any union worker with 20 years of service and 45 years of age, as of March 10, 1993, the date on which the collective bargaining agreement then in effect expired, would be entitled to receive an immediate and full pension (the creep provision). Two years after their employment with SKF was terminated, and prior to the submission of pension applications, Appellees commenced a breach of contract action against SKF alleging that throughout the course of their employment with the Company, they were employed under the same or better terms and conditions, including "pension eligibility," as SKF’s union workers. Upon review of the trial court record, the Supreme Court found that Appellees' claim was preempted, and accordingly reversed the Superior Court's order that affirmed the trial court's denial of summary judgment in favor of SKF. View "Barnett v. SKF USA, Inc." on Justia Law
Appeal of A&J Beverage Distribution, Inc.
Respondent A&J Beverage Distribution, Inc. appealed decisions of the Department of Labor (DOL) brought under the Whistleblowers' Protection Act by Petitioner Kevin Perrier. Petitioner worked for A&J as a truck driver. When he first started working, Petitioner did not participate in the company health plan. When premiums increased, Petitioner opted out of the plan. In 2009, rates decreased, and Petitioner claimed he was not informed of the decrease. When he sought information on the plan at that time, the company refused to give it to him. Petitioner notified the company that he had contacted the federal Department of Labor to learn more about his rights under ERISA with regard to notification of the company health plan. A&J then gave Petitioner the requested information, but shortly thereafter, he was terminated. The New Hampshire DOL hearing officer ruled that Petitioner "sustained his burden of proof to show that he was discharged in retaliation for having exercised his legitimate rights under the law." On appeal, A&J asserted preemption: that the whistleblower claim was preempted by ERISA. Upon review, the Supreme Court vacated the DOL's decision: "while the petitioner correctly notes that state and federal courts have concurrent jurisdiction over actions... his whistleblower claim is not such an action. ... [the Court] reject[ed] the petitioner's argument that DOL had jurisdiction over the petitioner's ERISA claim." View "Appeal of A&J Beverage Distribution, Inc. " on Justia Law