Justia ERISA Opinion Summaries

Plaintiff filed suit against UHS under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132, seeking to recover unpaid benefits. The Eighth Circuit held that plaintiff could not bring claims for benefits due to her husband in her personal capacity, but rather, a legal representative of her husband's estate must bring the claim. Furthermore, plaintiff could not bring a section 1132(a)(3)(B) claim in equity. However, a restitutionary claim for premiums she paid under section 1132(a)(3)(B) was potentially available to her if there was a plan violation. The court remanded to the district court to determine initially if there was such a plan violation and, if so, whether restitution of plaintiff's premiums was "appropriate equitable relief" under section 1132(a)(3)(B). The court also held that the district court did not err in determining that UHS was not the plan administrator and plaintiff's breach of contract claim was preempted by ERISA. View "Ibson v. United Healthcare Services" on Justia Law

The Fifth Circuit affirmed the district court's dismissal of plaintiff's claims, holding that the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132, preempted state law claims. The court held that, although the savings clause preserves a role for certain state laws that regulate insurance, state claims that provide a separate vehicle for seeking benefits from an ERISA plan remain preempted as such claims must be brought under ERISA's civil enforcement provision. The court explained that, otherwise, the exclusivity and uniformity of that federal remedy would be undermined. In this case, because plaintiff's claim for benefits must be brought under federal law, the district court correctly dismissed her state law claims seeking the same relief. Furthermore, the availability of that statutory remedy under section 502 of ERISA also defeated plaintiff's claim for equitable relief under federal law. View "Swenson v. United of Omaha Life Insurance Co." on Justia Law

A “top-hat” plan “which is unfunded and is maintained by an employer primarily for the purpose of providing deferred compensation for a select group of management or highly compensated employees,” 29 U.S.C. 1101(a)(1), 1051(2), 1081(a)(3), need not comply with many of the substantive provisions of the Employee Retirement Income Security Act of 1974 (ERISA). Sikora sought to recover pension benefits under ERISA through the University of Pittsburgh Medical Center and its Health System and Affiliates Non-Qualified Supplemental Benefit Plan. The district court held, and the Third Circuit affirmed, that he was not entitled to obtain such relief because he sought benefits under a top-hat plan. The courts rejected Sikora’s argument that the defendants were required to prove that plan participants had bargaining power before a court could conclude that he participated in a top-hat plan. Plan participant bargaining power is not a substantive element of a top-hat plan. View "Paul Sikora v. University of Pittsburgh Medical Center" on Justia Law

The Fourth Circuit affirmed the district court's denial of class certification and grant of summary judgment for CSC in an action filed by former executives pursuant to section 1132(a) of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs alleged denial of benefits under their deferred executive compensation plan after a plan amendment changed the applicable crediting rate, and sought class certification on behalf of all retired plan participants affected by the amendment. The court declined to decide which standards of review applied because the competing standards of review presented a distinction without a difference. Whether the court proceeded under a reasonableness inquiry, an abuse-of-discretion standard, or even de novo review, the 2012 Amendment and CSC's denial of benefits were valid. View "Plotnick v. Computer Sciences Corp." on Justia Law

The Supreme Court reversed the judgment of the district court granted summary judgment for New West Health Services (New West) in this action brought by Plaintiff and the class she represented alleging breach of contract, violation of made-whole rights, and unfair claims settlement practices. At issue in this appeal was the district court’s grant to New West leave to amend its answer to include the affirmative defense of ERISA preemption. The district court subsequently allowed Plaintiff to amended her complaint to include ERISA claims. Ultimately, the district court concluded that ERISA preemption required dismissal of Plaintiff’s state law and ERISA claims and entered summary judgment for New West. The Supreme Court reversed, holding that, under the extraordinary circumstances of this case, the district court abused its discretion by granting New West leave to amend its answer to assert ERISA preemption. View "Rolan v. New West Health Services" on Justia Law

The Ninth Circuit reversed the district court's denial of appellate attorney's fees under the Employee Retirement Income Security Act, 29 U.S.C. 1132(g)(1). The panel held that, pursuant to Sokol v. Bernstein, 812 F.2d 559, 561 (9th Cir. 1987), a court must consider the entire course of the litigation when analyzing a party's request for appellate attorney's fees within the Hummell v. S.E. Rykoff & Co., 634 F.2d 446 (9th Cir. 1980), rubric. Accordingly, the panel remanded to the district court for calculation of a reasonable award of fees and costs. View "Micha v. Sun Life Assurance of Canada" on Justia Law

Section 1113(1)'s statute of repose in the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 11131(a), is subject to express waiver. In this interlocutory appeal, the Eleventh Circuit was asked to answer a certified question regarding whether defendant was capable of expressly waiving the six-year statute of repose pursuant to section 1113(1). The court answered the certified question in the affirmative. The court reasoned that, because section 1113(1) does not erect a jurisdictional bar, it was presumptively waivable. Moreover, the court explained that there was no good reason to conclude that section 1113(1) cannot be expressly waived simply because it is a statute of repose. The court remanded for further proceedings. View "Secretary, U.S. Department of Labor v. Preston" on Justia Law

Plaintiffs filed suit against defendants, challenging the management of a defined benefit pension plan under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs alleged that defendants violated sections 404, 405, and 406 of ERISA by breaching their fiduciary obligations and causing the Plan to engage in prohibited transactions with a U.S. Bank subsidiary, FAF Advisors. The Eighth Circuit affirmed the district court's dismissal of the case as moot based on the Plan's overfunded status where there was no actual or imminent injury to the Plan itself that caused injury to plaintiffs' interests; dismissal of the Equities Strategy claim on statute-of-limitations and pleading grounds; and dismissal of plaintiffs' motion for attorneys' fees and costs. View "Thole v. U.S. Bank" on Justia Law

This case arose out of an underlying action to enforce the health benefits provisions of two court-approved settlement agreements. The Fourth Circuit affirmed the district court's denial of plaintiffs' motion for a preliminary injunction. The court held that a motion for preliminary injunction filed before the act to be enjoined has occurred, and subsequently intended to restore the status quo once it has been disturbed, was not moot. The court also held that the district court had jurisdiction over plaintiffs' claim pursuant to Section 502(a)(1)(B) of the Employee Retirement Income Security Act (ERISA). On the merits, the court held that the district court did not abuse its discretion in finding that plaintiffs failed to demonstrate a likelihood of success on the merits; that they were likely to suffer irreparable harm without a preliminary injunction; and that the balance of the equities and the public interest favor an injunction. View "Di Biase v. SPX Corp." on Justia Law

The Ninth Circuit reversed the district court's judgment in favor of MetLife in an action filed by plaintiff to seek life insurance benefits under a benefits plan governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The panel held that MetLife waived the evidence of insurability requirement because it did not ask plaintiff for a statement of health, even as it accepted her premiums for $250,000 in coverage. In this case, MetLife's purported ignorance of the facts did not negate its obligation to pay the entire $250,000 because, under agency law, the policyholder-employer's knowledge and conduct may be attributed to MetLife. View "Salyers v. Metropolitan Life Insurance Co." on Justia Law