Justia ERISA Opinion Summaries

In these consolidated cases, out-of-network medical providers who United intentionally failed to fully pay for services rendered to United plan beneficiaries in order to offset overpayments to the same providers from other United administered plans filed a class action under the Employee Retirement Income Security Act (ERISA) on behalf of their patients, the plan beneficiaries. Providers claimed that the relevant claim plan documents did not authorize United to engage in cross-plan offsetting.The Eighth Circuit affirmed the district court's grant of partial summary judgment to providers on the issue of liability and held that nothing in the plan documents even comes close to authorizing cross-plan offsetting. Furthermore, the practice of cross-plan offsetting was in some tension with the requirements of ERISA. While the court need not decide whether cross-plan offsetting necessarily violated ERISA, the court held that United's interpretation of the documents was not reasonable. View "Louis J. Peterson, D.C. v. UnitedHealth Group Inc." on Justia Law

In this action under the Employee Retirement Income Security Act (ERISA), the Second Circuit affirmed the district court's decision ordering Xerox and others to recalculate plaintiffs' retirement benefits as a matter of equitable reformation and to pay prejudgment interest at the federal prime rate. The court held that the district court did not abuse its discretion by selecting the new hire approach as an equitable remedy to redress the Plan Administrator's notice violations. The court affirmed the district court's decision to use the prime rate because the district court had broad discretion to grant prejudgment interest and to select a rate; carefully considered all the relevant factors in determining whether prejudgment interest was warranted, and, if so, what the rate should be; and thoroughly explained its reasoning for using the federal prime rate. View "Frommert v. Conkright" on Justia Law

Plaintiff filed suit against the plan administrator for Xerox under the Employee Retirement Income Security Act (ERISA) for denial of benefits and breach of fiduciary duty. The Second Circuit held that plaintiff's denial of benefits claim was untimely and that the administrator, not plaintiff, was entitled to summary judgment on the fiduciary duty claim.The court held that a litigant may not bring a denial‐of‐benefits claim under ERISA when the limitations period is six years and his claim accrued twelve years before he sued. The court also held that Frommert v. Conkright, 433 F.3d 254 (2d Cir. 2006), did not order the plan administrator not to apply the so‐called "phantom account offset" to plan participants who did not bring timely denial of benefits claims. Accordingly, the court affirmed in part, reversed in part, and remanded for directions to enter judgment for the administrator and the Xerox Plan. View "Testa v. Becker" on Justia Law

Plaintiffs appealed the district court's dismissal of their action against fiduciaries of IBM's employee stock option plan (ESOP), claiming that defendants violated their duty under the Employee Retirement Income Security Act (ERISA) to manage the ESOP's assets prudently. The Second Circuit reversed the district court's judgment against plaintiffs, holding that plaintiffs plausibly pleaded a duty‐of‐prudence claim even under the stricter "could not have concluded" test used by the district court. In this case, a prudent fiduciary in the Plan defendants' position could not have concluded that corrective disclosure would do more harm than good. View "Jander v. International" on Justia Law

The Ninth Circuit affirmed the district court's judgment against Quad in an action brought under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA). In this case, after the last of Quad's employees voted to decertify the union as their bargaining representative, Quad completely withdrew from the fund. The panel held that the Fund correctly applied the partial withdrawal credit pursuant to 29 U.S.C. 1386(b) against Quad's complete withdrawal liability before calculating the twenty-year limitation on annual payments provided for in 29 U.S.C. 1399(c)(1)(B). View "GCIU-Employer Retirement Fund v. Quad/Graphics, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Proctor and Gamble in an action brought by an employee under the Employee Retirement Income Security Act (ERISA) after his disability benefits were terminated. The court held that plaintiff possessed the information necessary to litigate his claim and was thus not prejudiced by any procedural irregularities; the company did not abuse its discretion in denying plaintiff's claim for benefits where the denial letter adequately stated the reasons for supporting its decision; and the company's interpretation of the plan was reasonable and there was substantial evidence to support its decision. The court held that plaintiff's remaining claims were unavailing and the district court did not abuse its discretion by denying plaintiff's request for statutory penalties. View "Leirer v. Procter & Gamble Disability Benefit Plan" on Justia Law

Scott Brain, a former trustee of the Trust Funds, and the Cook Defendants appealed the district court's entry of judgment against them in a civil enforcement action by the Secretary of the Department of Labor for violations of the Employee Retirement Income Security Act (ERISA).The Ninth Circuit affirmed in part and held that the district court did not err in concluding that Brain violated ERISA section 510 by retaliating against a whistleblower. The panel vacated and reversed in part and held that the district court erred in concluding that Brain breached his fiduciary duty in violation of ERISA section 404 by placing the whistleblower on administrative leave. The panel also held that the district court erred in basing the permanent injunction on ERISA section 409; ERISA section 502(a)(5) did not provide an alternative basis for the district court's permanent injunction; the district court did not err in determining that the Cook Defendants were not immune under the attorney immunity doctrine; and the Cook Defendants' remaining arguments were meritless. View "Acosta v. Brain" on Justia Law

A former employee and participant in Intel’s retirement plans sued the company for allegedly investing retirement funds in violation of ERISA section 1104. The district court dismissed the action as untimely, concluding that the employee had the requisite “actual knowledge” to trigger ERISA’s three-year limitations period, 29 U.S.C. 1113(2). The Ninth Circuit reversed. A two-step process is followed in determining whether a claim is barred by section 1113(2): the court isolates and defines the underlying violation on which the plaintiff’s claim is founded; the court then inquires whether the plaintiff had “actual knowledge” of the alleged breach or violation. Actual knowledge does not mean that a plaintiff had knowledge that the underlying action violated ERISA, nor does it merely mean that a plaintiff had knowledge that the underlying action occurred. The defendant must show that the plaintiff was actually aware of the nature of the alleged breach more than three years before the plaintiff’s action was filed. In an ERISA section 1104 case, the plaintiff must have been aware that the defendant had acted and that those acts were imprudent. Disputes of material fact as to the plaintiff’s actual knowledge precluded summary judgment. View "Sulyma v. Intel Corp. Investment Policy Committee" on Justia Law

Dr. Griffin provided medical care to T.R., a participant in a Central States health plan. Before receiving treatment, T.R. assigned to Griffin the rights to “pursue claims for benefits, statutory penalties, [and] breach of fiduciary duty ….” Griffin confirmed through a Central representative that the plan would pay for the treatment at the usual, reasonable, and customary rate, then treated T.R. and submitted a claim for $7,963. Griffin later challenged the benefits determination, requesting a copy of the summary plan description and documents used to determine her payment. Six months later, Central responded that iSight, a third party, used “pricing methodology” to determine the fee and telling her to negotiate with iSight before engaging in the appeals process that the plan required before a civil suit. Griffin missed a call from iSight, returned the call, and left a message that she “would not take any reductions.” iSight never called back. Central provided a copy of the summary plan description, but no fee schedules or tables. Griffin sued under ERISA, 29 U.S.C. 1132(a)(1)(B), (a)(3), alleging that Central did not pay her the proper rate under the plan; breached its fiduciary duty by not adhering to plan terms; and failed to produce, within 30 days, the summary plan description she requested, nor iSight’s fee schedules. The court dismissed. The Seventh Circuit affirmed in part and vacated in part. Griffin adequately alleged that she is eligible for additional benefits and statutory damages. View "Griffin v. Teamcare" on Justia Law

Dr. McCann, a radiologist certified in the specialty of interventional radiology, purchased a supplemental long-term disability insurance policy from Provident. After initially issuing payments under the policy, Provident terminated Dr. McCann’s disability benefits based on a determination that Dr. McCann was primarily practicing as a diagnostic radiologist—rather than as an interventional radiologist—at the time he became disabled. The Third Circuit remanded for a determination of whether to consider whether Dr. McCann’s medical conditions prevent him from being able to perform his “substantial and material duties” as an interventional radiologist, as required by the terms of the policy. The court concluded that the claim was governed by the Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001. The Department of Labor has promulgated a safe harbor regulation exempting certain plans from the definition of an “employee welfare benefit plan” but McCann’s then-employer sufficiently endorsed the plan under which his policy was purchased to render the safe harbor inapplicable. Provident incorrectly defined Dr. McCann’s occupation in administering his disability claim; the claim must be evaluated in the context of his specialty—interventional radiology. View "McCann v. Unum Provident" on Justia Law