Justia ERISA Opinion Summaries

The First Circuit affirmed the judgment of the district court concluding that the denial of Plaintiff's disability benefits claim violated the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., holding that Aetna Life Insurance Company's decision to deny Plaintiff's benefits claim was arbitrary and capricious.Plaintiff employed for benefits under his employer's long-term disability benefits plan, which Aetna administered and funded, after Plaintiff was diagnosed with malignant melanoma. Aetna denied the application under the plan's exclusion for disabilities caused by pre-existing conditions. Plaintiff subsequently brought this action. The district court entered judgment for Plaintiff and awarded him back benefits, interest, fees, and costs. The First Circuit affirmed, holding that an unconflicted fiduciary would likely have found coverage. The Court remanded the case for any further proceedings that may be necessary. View "Lavery v. Restoration Hardware Long Term Disability Benefits Plan" on Justia Law

MetLife and Ford appealed the district court's award of benefits, costs and attorney fees in an Employee Retirement Income Security Act (ERISA) action. In this case, while MetLife paid plaintiff her husband's basic life insurance benefit, it denied payment of an optional life insurance (OLI) benefit.The Eighth Circuit affirmed in part and reversed in part, holding that the district court erred in finding that there was no substantial evidence supporting MetLife's denial of OLI benefits, because substantial evidence supported MetLife's assertion that the husband answered an online questionnaire averring that he had not been treated for high blood pressure, when in fact he had. The court also held that there was substantial evidence in the record to support MetLife's reliance upon the plan administrator's representations that the husband would not have been automatically enrolled in the OLI program if he had truthfully answered the high blood pressure question in the screening questionnaire; the OLI benefits could not have been awarded on an equitable estoppel theory; the district court did not abuse its discretion by denying statutory penalties for the delay in providing documents; and attorney fees and costs must be reversed and remanded. View "Sepulveda-Rodriguez v. Metropolitan Life Insurance Co." on Justia Law

The Ninth Circuit reversed the district court's order denying Schwab's motion to compel arbitration in a class action brought by a former participant in an Employee Retirement Income Security Act (ERISA) retirement plan. Plaintiff alleged that defendants violated ERISA and breached their fiduciary duties by including Schwab-affiliated investment funds in the Plan—despite the funds' poor performance—to generate fees for Schwab and its affiliates.In light of the Supreme Court's intervening case law, the panel held that its holding in Amaro v. Continental Can Co., 724 F.2d 747 (9th Cir. 1984), that ERISA claims were not arbitrable, was no longer good law. The panel held that the holding in American Express Co. v. Italian Colors Restaurant, 570 U.S. 228 (2013), that federal statutory claims are generally arbitrable and arbitrators can competently interpret and apply federal statutes, was irreconcilable with Amaro. Accordingly, the court remanded. View "Dorman v. The Charles Schwab Corp." on Justia Law

Plaintiffs filed suit under the Employee Retirement Income Security Act (ERISA), alleging that NMSC failed to make the required contributions from 2008 to 2015. The Second Circuit vacated the district court's final judgment in favor of plaintiffs.The court clarified, consistent with circuit and Supreme Court precedent, that an employer in an ERISA action for unpaid contributions is bound to the terms of an ERISA plan document (the Trust Agreement in this case) only if the employer objectively manifests an intent to be so bound, as evaluated under ordinary principles of contract interpretation. The court applied these principles here and held that NMSC did not bind itself to the Trust Agreement -- and the interest rate established under its Delinquency Policy -- until NMSC agreed to the Memorandum of Agreement modifying the collective bargaining agreement in 2014. The court also rejected the Fund's alternative argument that applying ERISA‐plan‐based interest provisions is so fundamental to the functioning of a fund that its trustees may unilaterally impose such provisions on a delinquent employer. View "32BJ North Pension Fund v. Nutrition Management Services, Co." on Justia Law

The Ninth Circuit affirmed the district court's grant of summary judgment in an Employee Retirement Income Security Act (ERISA) action challenging the denial of plaintiff's request for early retirement benefits. Plaintiff argued that the Board incorrectly interpreted the Plan to deny his application for benefits.The panel held that any procedural irregularities in the Board's actions were minor and, at most, the Board's actions weigh only slightly and weakly in favor of holding that an abuse of discretion occurred here. The panel also held that the Board did not abuse its discretion by interpreting "performance of services in any capacity in the Electrical Industry" to include working for the union. In this case, in light of Tapley v. Locals 302 & 612 of Int'l Union of Operating Eng'rs-Emp'rs Const. Indus. Ret. Plan, the panel held that the Board's interpretation did not clearly conflict with the Plan's language; did not render any other Plan provision nugatory; and did not lack a rational nexus to the Plan's purpose. Therefore, the Board's interpretation of the Plan was reasonable. View "O'Rourke v. Northern California Electrical Workers Pension Plan" on Justia Law

Unions set up a pension plan under the Employment Retirement Income Security Act, 29 U.S.C. 1001, with electrical contractors (Revcon) sharing ownership. Revcon withdrew from the plan in 2003. The Multiemployer Pension Plan Amendments Act, 29 U.S.C. 1381, requires employers who withdraw from underfunded pension plans to pay withdrawal liability. The trustees notified Revcon of $394,788 in withdrawal liability and demanded quarterly payments of $3,818. Revcon missed several payments. The trustees accelerated the outstanding liability (29 U.S.C. 1399(c)(5)) and filed suit. Revcon offered to cure its defaults and resume payments. The trustees agreed and voluntarily dismissed the suit under FED. R. CIV. P. 41(a). Revcon made some payments, then defaulted again. The trustees again sued. Revcon again promised to cure; the trustees again voluntarily dismissed. This cycle repeated in 2011, 2013, and 2015. In 2018, after another default, the trustees filed this case, which, unlike previous complaints, only the payments that Revcon had missed since the 2015 dismissal.Revcon argued claim preclusion because the previous complaints demanded the entire liability, which necessarily includes the defaulted payments at issue. The “two dismissal rule” of Rule 41(a)(1)(B) therefore barred any claims arising from that liability, and, because the trustees sought to collect the entire debt in 2008, the six-year limitations period had expired. The trustees countered that they revoked the 2008 acceleration with each dismissal and that the two dismissal rule did not apply because all parties consented to the previous dismissals. The Seventh Circuit found the case untimely, noting that the earlier complaints all stated the withdrawal liability was accelerated in 2008, contradicting an argument that acceleration had been revoked. The statute makes no mention of such a deceleration mechanism. View "Bauwens v. Revcon Technology Group, Inc." on Justia Law

In 1880, the Sisters, a Roman Catholic organization, founded OSF, which provides healthcare to indigent patients. The Sisters maintain authority through OSF’s governing documents and canonical and civil guidelines pertaining to church property. OSF merged with another Catholic hospital with the permission of the Holy See. Both offered employee pension plans before the merger. The Plans, with 19,285 participants, are now closed to new participants. Smith, a former employee and OSF plan participant, sued, claiming that the plans are not eligible for the church plan exemption under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 because they are administered by Committees that are not “principal-purpose organizations” and that the exemption itself is unconstitutional. She alleged that OSF allowed the plans to become severely underfunded; failed to follow notice, disclosure, and managerial requirements; and breached its fiduciary duties. The district court granted the defendants summary judgment despite plaintiff’s Federal Rule of Civil Procedure 56(d) motion to postpone the decision so that she could complete further discovery. The Seventh Circuit vacated. The summary judgment motion was filed long before discovery was to close; plaintiff was pursuing discovery in a diligent, sensible, and sequenced manner; and the pending discovery was material to summary judgment issues. The court’s explanation for denying a postponement overlooked earlier case-management and scheduling decisions and took an unduly narrow view of relevant facts. View "Smith v. OSF Healthcare System" on Justia Law

Bergamatto began working as a longshoreman in 2000 and stopped working in 2010. In 2013, he applied for retirement benefits under his pension plan, which is covered by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001. The 2010 plan said that “[t]he provisions … in effect during the Participant’s last year of credited service shall be applied to determine the Participant’s right to benefits and the amount thereof.” The 2010 plan originally precluded longshoremen hired between October 1996 and September 2004 from accruing benefits for work performed before October 2004. A 2013 amendment to the 2010 plan provided that, “[e]ffective October 1, 2012, Participants hired on or after October 1, 1996 shall receive pension benefit accruals for years of credited service earned from 1996 through 2004[.]” A 2015 plan eliminated the language preventing employees hired between October 1996 and September 2004 from accruing benefits for work prior to October 2004. Bergamatto’s application for pension benefits was approved based on only the years of credited service starting in October 2004 on the basis that the 2010 plan required that benefit determinations be made based on the plan provisions in force during the participant’s last year of credited service. The fund’s Board of Trustees agreed. The Third Circuit affirmed summary judgment in favor of the defendants, finding the Board of Trustees’ interpretation of the 2015 and 2010 plans “reasonably consistent” with the plans’ unambiguous language. View "Bergamatto v. Board of Trustees of NYSA-ILA Pension Fund" on Justia Law

This appeal involved one type of partial withdraw under the Multiemployer Pension Plan Amendments Act (MPPAA): "bargaining out," which occurs when an employer permanently ceases to have an obligation to contribute under one or more but fewer than all collective bargaining agreements under which the employer has been obligated to contribute but continues to perform work of the type for which contributions were previously required.The Third Circuit affirmed the district court's judgment and held that, under 29 U.S.C. 1385(b)(2)(A)(i), "work . . . of the type for which contributions were previously required" does not include work of the type for which contributions are still required. In this case, because CEC continues to contribute to its pension plan for engineering work at its remaining three casinos, it was not liable under section 1385(b)(2)(A)(i). View "Caesars Entertainment Corp. v. International Union of Operating Engineers Local 68 Pension Fund" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment to Sun Life in an action brought by plaintiff, a beneficiary of a long-term disability plan governed by the Employee Retirement Income Security Act of 1974 (ERISA) and administered by Sun Life, alleging that Sun Life had miscalculated his benefits since 2008. The district court agreed with Sun Life that the contractual limitations period for plaintiff's claim had long since passed.The court affirmed the district court's conclusion that no genuine issues of material fact exist as to plaintiff's receipt of the March 2008 letter and that the letter contained enough information for plaintiff's miscalculation claim to accrue. Furthermore, Withrow v. Halsey, 655 F.3d 1032 (9th Cir. 2011), in which the Ninth Circuit ruled that an ERISA miscalculation claim was timely despite a gap of many years between the plan and beneficiary's initial correspondence and the beneficiary's suit, did not help plaintiff and the district court did not abuse its discretion by denying the motion. View "Faciane v. Sun Life Assurance Co." on Justia Law