Justia ERISA Opinion Summaries

The Eighth Circuit reversed the district court's judgment against Liberty Life in an action filed by plaintiff under the Employee Retirement Income Security Act (ERISA), alleging that the company's denial of long-term disability benefits under his employer's welfare plan was an abuse of discretion. The court held that Liberty Life's decision was not an abuse of discretion because the medical opinions the district court rejected were supported by medical evidence and were sufficiently reliable to provide a reasonable basis for defendant to deny the claim. The court also vacated the award of attorney's fees. View "Zaeske v. Liberty Life Assurance Company of Boston" on Justia Law

Plaintiffs filed suit against Anderson Excavating under 29 U.S.C. 185(a), 29 U.S.C. 1132, and 29 U.S.C. 1145, requesting that the district court order Anderson Excavating to pay the contributions it allegedly owed to the Welfare Plan and Pension Plan, along with interest, liquidated damages, and attorneys' fees and costs.The Eighth Circuit held that the district court erred in determining damages for unpaid contributions, prejudgment interest, liquidated damages, and attorneys' fees; the district court legally erred in applying the alter ego doctrine to justify an award of unpaid contributions for an alleged employee's work; and thus the court reversed the judgment of the district court and remanded for further proceedings. View "Marshall v. Anderson Excavating & Wrecking" on Justia Law

In 2005, Delta Airlines filed for bankruptcy and stopped contributing to its pilots' pension plan. Delta and the Pension Benefit Guaranty Corporation (PBGC) terminated that Plan, which had insufficient assets to support promised benefit payments, Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1301-1461. Under such circumstances, a trustee collects the remaining assets and makes promised payments according to statutory priorities. PBGC provides additional money from its own funds to make up the difference between those payments and guaranteed benefits. PBGC, the Plan's trustee, determined the Plan had a deficit of over $2.5 billion, almost $800 million of which PBGC guaranteed, and paid estimated benefits. It took six years to finalize benefit determinations. After administrative appeals by the pilots, nearly 1,700 beneficiaries sued to further challenge those determinations, citing the Administrative Procedure Act, 5 U.S.C. 706, and seeking disgorgement, arguing that the Corporation breached its fiduciary duty and controlled Plan assets for a longer period to collect “massive investment returns” rather than timely paying the pilots. The D.C. Circuit reversed the denial of the Corporation’s motion to dismiss the breach of fiduciary duty claim. Recovering the post-termination increase in the value of plan assets is not an available remedy; 29 U.S.C. 1344(c) prevents disgorgement, providing that “[a]ny increase or decrease in the value of the assets of a single-employer plan occurring after the date on which the plan is terminated shall be credited to, or suffered by, the [C]orporation.” View "Lewis v. Pension Benefit Guaranty Corp." on Justia Law

Springer, a Utah physician, began a fellowship at the Cleveland Clinic and enrolled his family in its employee benefit plan, administered by Antares. During the enrollment period, Springer had his 14-month-old son, J.S., transported from a Utah hospital to the Cleveland Clinic by Angel Jet’s air ambulance service. J.S. had been hospitalized since birth for multiple congenital abnormalities. He required a mechanical ventilator. J.S.’s physician prepared a letter of medical necessity for the service. Before the flight, Angel Jet contacted Antares, which was unable to confirm that Springer and his son were members of the plan and did not precertify the service. Angel Jet proceeded with the transportation and submitted a bill to Antares for $340,100. Antares denied it for failure to obtain precertification. The Plan affirmed the denial but paid $34,451.75, reflecting the amount their preferred provider would have charged. Angel Jet brought suit under the Employee Retirement Security Act. The district court dismissed the suit, finding that Springer had not properly assigned his rights under the plan to Angel Jet. Springer then brought his own claim under ERISA Section 502(a)(1)(B). The Sixth Circuit affirmed, first finding that Springer had standing despite having received the service and not being billed. The denial was not arbitrary and capricious because J.S.’s transportation was not an emergency or precertified as required for a nonemergency. View "Springer v. Cleveland Clinic Employee Health Plan Total Care" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's complaint for failure to state a claim. Plaintiff alleged that his former employer, Wells Fargo, breached their fiduciary duty under the Employment Retirement Income Security Act (ERISA). The court held that the district court correctly determined that plaintiff's omission of any meaningful benchmark in his complaint meant that he failed to allege any facts showing the Wells Fargo Target Date Funds were an imprudent choice. In this case, plaintiff did not plead that the Funds were underperforming and his conclusory allegations of bad conduct did not save the complaint from its deficient pleading. Therefore, plaintiff failed to state a claim for relief under ERISA. View "Meiners v. Wells Fargo & Co." on Justia Law

NCMC filed suit alleging that Aetna underpaid out-of-network providers like NCMC in violation of the Employee Retirement Income Security Act of 1974 (ERISA) and Texas law. Aetna counterclaimed, alleging that NCMC fraudulently and negligently misrepresented its billing practices by routinely waiving patient responsibilities yet billing Aetna for the total out-of-network cost.The Fifth Circuit held that Aetna's reliance on any alleged misrepresentation by NCMC was not justifiable and Aetna failed to establish a conflict in substantial evidence on this element of its fraud and negligent representation claims; any error in excluding Aetna's damages expert was harmless, and the district court did not abuse its discretion in excluding evidence of physician compensation; the district court abused its discretion by denying Aetna leave to amend without providing reasons; but denial of leave to amend was warranted because Aetna's counterclaims were untimely and unduly prejudicial to NCMC. In regard to NCMC's cross-appeal, the court held that any error in denying NCMC's motion to compel was harmless; the district court therefore did not err in granting Aetna's Rule 52(c) motion for judgment as a matter of law; but the district court's order denying attorney fees must be vacated and remanded for an explanation. Accordingly, the court affirmed in part, reversed in part, and remanded. View "North Cypress Medical Center Operating Co. v. Aetna Life Insurance Co." on Justia Law

The Fourth Circuit affirmed the district court's grant of summary judgment to Hartford Life in an action brought under the Employee Retirement Income Security Act (ERISA). Plaintiff filed suit seeking a continuation of the long-term disability benefits that Hartford Life had terminated based on its conclusion that plaintiff was no longer "disabled," as that term was used in the plan. The court affirmed the district court's conclusion that Hartford Life, not Hartford Fire, determined that plaintiff was no longer eligible for long-term disability benefits, and Hartford Life's decision to terminate his long-term disability benefits was not an unreasonable exercise of discretion. In this case, the record demonstrated that plaintiff received a fair and thorough consideration of his claim and Hartford Life's conclusion was reasonably supported by the available evidence where, among other things, video surveillance evidence showed plaintiff walking at a quick pace and moving without observable bracing or support. View "Griffin v. Hartford Life & Accident Insurance Co." on Justia Law

Current and former employees of the University of Southern California may not be compelled to arbitrate their collective claims for breach of fiduciary responsibility against USC in an action under the Employee Retirement Income Security Act (ERISA). The Ninth Circuit affirmed the district court's denial of USC's motion to compel arbitration of claims for breach of fiduciary duty in the administration of two ERISA plans. The panel held that the district court properly denied USC's motion to compel arbitration where the claims asserted on behalf of the Plans in this case fell outside the scope of the arbitration clauses in individual employees' general employment contracts. View "Munro v. University of Southern California" on Justia Law

Cehovic’s employer offered its employees an insurance benefit plan through ReliaStar. Cehovic had two ReliaStar policies: a basic policy with a death benefit of $263,000, and a supplemental policy with a death benefit of $788,000. Both listed his sister, Cehovic‐Dixneuf, as the sole and primary beneficiary. After Cehovic died, his ex‐wife claimed that she and the child she had with Cehovic were entitled to the death benefits from the supplemental policy. The district court granted summary judgment for Cehovic‐Dixneuf. The Seventh Circuit affirmed. The Employee Retirement Income Security Act (ERISA) requires administrators of employee benefit plans to comply with the documents that control the plans, 29 U.S.C. 1104(a)(1)(D). For life insurance policies, that means death benefits are paid to the beneficiary designated in the policy, notwithstanding equitable arguments or claims that others might assert. The supplemental policy is governed by ERISA even though Cehovic paid all of its premiums without any direct subsidy from the employer. Cehovic’s employer performed all administrative functions associated with the maintenance of the policy. The plan description made clear that the supplemental life insurance policy would remain part of the employer’s group policy, but could be converted to an individual policy in certain situations. Nothing in the record shows that Cehovic executed a conversion. View "Cehovic-Dixneuf v. Wong" on Justia Law

The Second Circuit affirmed the district court's dismissal of plaintiff's Employee Retirement Income Security Act (ERISA) complaint for failure to state claims for which relief can be granted. Plaintiffs challenged the conduct of twelve banks and their affiliates in the FX market from January 2003 through 2014. On de novo review, the court held that plaintiffs failed to state plausible ERISA claims because the facts alleged do not show that defendants exercised the control over Plan assets necessary to establish ERISA functional fiduciary status. Furthermore, the court found no abuse of discretion in the district court's denial of adjournment or leave to file a fourth amended complaint. View "Allen v. Credit Suisse Securities (USA) LLC" on Justia Law