Justia ERISA Opinion Summaries

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

The Fourth Circuit vacated the district court's dismissal of plaintiff's action against NCG, which alleged two claims under the Employee Retirement Income Security Act of 1974 (ERISA). Plaintiff alleged that NCG breached its fiduciary duties in the administration of a group life insurance plan in which plaintiff's late husband had enrolled and for which NCG was the "named fiduciary."The court held that the complaint sufficiently alleged NCG's fiduciary status in relation to plaintiff's ERISA claims. In this case, the complaint showed that NCG acted as a function fiduciary when it failed to inform or misinformed plaintiff's husband about the continued eligibility under the plan, and NCG neglected to notify her husband that he had the option to convert or port his life insurance coverage. Furthermore, NCG breached the fiduciary duty that it owed to plaintiff as a beneficiary when Vice President Baham advised her not to appeal Unum Life's denial of her benefits claim. Accordingly, the court remanded for further proceedings. View "Dawson-Murdock v. National Counseling Group, Inc." on Justia Law

The Eighth Circuit affirmed the district court's dismissal of Air Evac's claims in an action alleging that Arkansas Blue inadequately reimbursed Air Evac for ambulance services that Air Evac provided Arkansas Blue plan members. The court held that Air Evac's assignment did not convey the right to sue for equitable relief under section 1132(a)(3) of the Employee Retirement Income Security Act (ERISA). Furthermore, the district court did not err by finding that Arkansas Blue's conduct was not actionable because it fell within the Arkansas Deceptive Practices Act's safe harbor for actions or transactions permitted under the laws administered by the insurance commissioner. Finally, the district court did not err by rejecting Air Evac's claims for breach of contract and unjust enrichment. View "Air Evac EMS, Inc. v. USAble Mutual Insurance Co." on Justia Law

Knox-Bender suffered injuries from a car accident. She sought medical treatment at Methodist Healthcare. Methodist billed her $8,000 for the treatment. Payments to Methodist were made on Knox-Bender’s behalf by her employer-sponsored healthcare plan, her automobile insurance plan, and her husband’s healthcare plan. Knox-Bender says that the insurance plans had already agreed with Methodist on the price of her care. She claims that, despite this agreement, Methodist overcharged her and that this was common practice for Methodist. She and a putative class of other patients, sued in Tennessee state court. During discovery, Methodist learned that Knox-Bender’s husband’s healthcare plan was an ERISA plan, 29 U.S.C.1001(b) that covered $100 of her $8,000 bill. Methodist removed the case to federal court claiming complete preemption under ERISA. The district court denied Knox-Bender’s motion to remand and entered judgment in favor of Methodist. The Sixth Circuit reversed. The complete preemption of state law claims under ERISA is “a narrow exception to the well-pleaded complaint rule.” Methodist has not met its burden to show that Knox-Bender’s complaint fits within that narrow exception. Since Knox-Bender has not alleged a denial of benefits under her husband’s ERISA plan, ERISA does not completely preempt her claim. Even if Methodist had shown that Knox-Bender alleged a denial of benefits, it would also have show that Knox-Bender complained only of duties breached under ERISA, not any independent legal duty. View "K.B. v. Methodist Healthcare - Memphis Hospitals" on Justia Law

Plaintiff filed suit against Safelite for breach of contract and negligent misrepresentation arising from the company's alleged mismanagement of its deferred compensation plan for executive employees. The Sixth Circuit affirmed the district court's grant of Safelite's motion for partial summary judgment, holding that the Safelite Plan qualifies as an employee pension benefit plan under 29 U.S.C. 1002(2)(A)(ii) and is not a bonus plan as defined in 29 C.F.R. 2510.3-2(c). Therefore, the Safelite Plan was not exempted from coverage under the Employee Retirement Income Security Act. View "Wilson v. Safelite Group, Inc." on Justia Law

The Fund filed suit claiming a delinquent exit from Four-C, a former participating employer, under section 515 of the Employee Retirement Income Security Act of 1974. The Fourth Circuit reversed the district court's grant of Four-C's motion to dismiss, holding that the Fund's governing agreements and Four-C's collective bargaining agreement (CBA) required participating employers to pay an exit contribution when they no longer have a duty to contribute to the Fund due to the expiration of the underlying CBA, and therefore the complaint alleged a viable claim. Accordingly, the court vacated the judgment as to the exit contribution claim and remanded for further proceedings. View "Board of Trustees v. Four-C-Aire, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to MBI in an action brought by MBI seeking reimbursement of the benefits it paid to defendant under a self-funded employee benefit plan sponsored and administered by MBI. The court held that the Employee Retirement Income Security Act allows a fiduciary such as MBI to bring an action for equitable relief to enforce the terms of an employee benefit plan.The court also held that MBI was entitled to reimbursement because the Summary Plan Description was the plan's written instrument and defendant did not dispute that its reimbursement provision required him to pay MBI if it was an enforceable part of the plan. The court rejected defendant's remaining claims. View "MBI Energy Services v. Hoch" on Justia Law