Justia ERISA Opinion Summaries

In Sprint Commc’ns, Inc. v. Jacobs, the Supreme Court revisited the doctrine of abstention enunciated in Younger v. Harris. That doctrine requires federal courts, in the absence of extraordinary circumstances, to refrain from interfering with certain state proceedings. In this case, David Knight, an employee of Sirva Relocation, LLC, filed a charge of discrimination with the Massachusetts Commission Against Discrimination (MCAD) alleging that Sirva and Aetna Life Insurance Company (together, Appellants) had discriminated against him on the basis of disability in violation of Mass. Gen. Laws ch. 151B and the Americans with Disabilities Act (ADA). Appellants filed a federal complaint against the Commonwealth of Massachusetts, the MCAD, its commissioners, and Knight, asking the court to enjoin the MCAD proceeding on the basis that ERISA preempted the chapter 151B claim. The MCAD and Knight moved to dismiss the complaint, entreating the district court to abstain. While the case was pending, the Supreme Court decided Sprint. The district court dismissed the federal court action, concluding that Younger abstention was appropriate in this case. The First Circuit affirmed the district court’s decision to abstain and further clarified its own case law concerning the exception to the Younger doctrine for facially conclusive claims of preemption. View "Sirva Relocation, LLC v. Golar Richie" on Justia Law

Plaintiff, a physician, filed suit alleging that his employer Montefiore denied him severance benefits in violation of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. The district court dismissed the complaint for lack of jurisdiction. The court concluded, however, that on the facts alleged in the complaint, the severance policy at issue is a "plan" governed by section 1002(1) of ERISA. The court considered Montefiore's remaining arguments and concluded that they are without merit. Accordingly, the court vacated and remanded. View "Okun v. Montefiore Medical Center" on Justia Law

Plaintiffs, physicians, filed suit against Cigna alleging that Cigna violated the anti-retaliation provisions of ERISA. Plaintiffs moved for a temporary restraining order and preliminary injunction to prohibit Cigna from terminating plaintiffs from its provider network. The district court denied the injunction and plaintiffs appealed. The court held that healthcare providers are not “beneficiaries” of an ERISA welfare plan by virtue of their in‐network status or their entitlement to payment. Patients may assign to their doctors the right to collect payment on their behalf in exchange for medical services, but the doctors in this case do not seek payment; instead, they seek to assert anti‐retaliation protections which were not assigned to them. Accordingly, the court affirmed the judgment. View "Henry L. Rojas, M.D. v. Cigna Health and Life Ins. Co." on Justia Law

Jeffrey Perelman is a participant in the defined employee pension benefit plan of GRC and alleges that his father, Raymond, as chairman of GRC and trustee of the Plan, breached his fiduciary duties by covertly investing Plan assets in the corporate bonds of struggling companies owned and controlled by Jeffrey’s brother, Ronald. Jeffrey claimed that these transactions were not properly reported; depleted Plan assets; and increased the risk of default, such that his own defined benefits are in jeopardy. The district court dismissed several claims for lack of standing; later granted summary judgment, rejecting all remaining claims; and denied Jeffrey attorneys’ fees and costs under the Employee Retirement Income Security Act, 29 U.S.C. 1132. The Third Circuit affirmed, rejecting arguments that Jeffrey had standing to seek monetary equitable relief such as disgorgement or restitution under ERISA section 502(a)(3) because he suffered an increased risk of Plan default with respect to his defined benefits, and in seeking relief on behalf of the Plan, no showing of individual harm was necessary. The court upheld the denial of attorneys’ fees and costs, rejecting claims that the lawsuit was a catalyst for the voluntary resolution of several issues, including Raymond’s resignation as Trustee. View "Perelman v. Perelman" on Justia Law

Plaintiff filed suit against National Union under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., which permits a beneficiary of an employee benefit plan to bring a civil action to recover benefits owed under the plan. Plaintiff claimed that her husband's death occurred as a result of an accident as defined by the policy. Plaintiff's husband died as a result of Deep Vein Thrombosis (DVT) shortly after he completed roughly 28 hours of air travel in a five-day period. The court concluded that regardless of whether the husband's death may be characterized as an externally caused “accident” when considering that word in isolation, his loss of life was not within the policy’s coverage. His fatal injury did not directly result from an unintended and unanticipated happening “external to the body.” Accordingly, the court affirmed the district court's grant of summary judgment for National Union. View "Williams v. Nat'l Union Fire Ins." on Justia Law

The Fund filed suit against Empire under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA), 29 U.S.C. §§ 1381–1453, after Empire effected a "complete withdrawal" from the Fund. Steven Levine was the sole shareholder of Empire. The Fund also filed suit against Enivel to recover on its judgment against Empire, alleging that Enivel is a trade or business under common control with Empire such that it is jointly and severally liable for Empire’s withdrawal liability. At issue was whether a separate business organization can be held responsible for the liabilities of another commonly controlled entity under the Employee Retirement Income Security Act of 1974 (ERISA), as amended by the MPPAA. The court concluded that, although Enivel and Empire are commonly controlled, Enivel’s limited leasing and sales activity was personal in nature - not primarily for profit - and Enivel did not operate continuously and regularly. The owners did not fragment their business operations over several entities. Rather, Enivel’s mission was primarily personal and any profit it derived was incidental. Therefore, the court concluded that Enivel is not a “trade or business” for the purposes of the MPPAA and affirmed the district court's judgment for Enivel. View "UFCW Local One Pension Fund v. Enivel Properties, LLC" on Justia Law

In these consolidated appeals, plaintiffs claimed that defendants breached their fiduciary duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001, et seq. While the appeals were pending, the Supreme Court issued its decision in Tibble v. Edison International, which held that a plaintiff can effectively allege that a defendant breached its duty of prudence under ERISA "by failing to properly monitor investments and remove imprudent ones[,] . . . [and] so long as the alleged breach of the continuing duty occurred within six years of suit, the claim is timely." The parties agreed that these cases should be remanded in light of Tibble. The court agreed and therefore vacated the judgments and remanded for further proceedings. The court declined to reassign the case to a new district judge. View "Pruitt v. Suntrust Banks, Inc." on Justia Law

After PSI stopped contributing to the Fund, a multiemployer pension benefit plan governed by the Employment Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., the Fund informed PSI that it owed "withdrawal liability" pursuant to section 1381. The Fund filed suit against PSI after PSI failed to pay the sum owed. The court affirmed the judgment, finding that the district court had personal and subject matter jurisdiction, venue was proper in Virginia, and PSI bound itself to make contributions to the Fund. View "Trustees of the Plumbers v. Plumbing Svc." on Justia Law

Kienstra, a Missouri resident, received treatment for uterine fibroid tumors at the Mayo Clinic in 2008. Her health plan concluded that her treatment fell outside the plan's coverage as experimental and requiring prior approval. Internal appeals failed. The plan is a self-funded multiple employer plan, maintained pursuant to collective bargaining agreements, and subject to the Employee Retirement Income Security Act, 29 U.S.C. 1002(1). The plan specified that any civil action for wrongful denial of medical benefits under ERISA must be filed within two years of the final date of denial. Kienstra filed suit almost two and a half years after she learned her claim had been denied. She unsuccessfully argued that the contractual limitations period was invalid because the plan's rules of construction stated that its terms should be read to comply with Missouri law, that a 10-year Missouri statute of limitations governed, and that a separate statute barred contracting parties from shortening that limitations period. The Eighth Circuit affirmed. There is no conflict between the plan's contractual limitations period and Missouri law; state law does not "apply of its own force to a suit based on federal law—especially a suit under ERISA, with its comprehensive preemption provision." View "Munro-Kienstra v. Carpenters' Health & Welfare Trust Fund of St. Louis" on Justia Law

Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., seeking disgorgement from an employer who wrongly transferred assets from a pension plan that enjoyed a separate account feature to a pension plan that lacked one. The district court dismissed the complaint, holding that plaintiffs lacked statutory and Article III standing. The court held, however, that a defined contribution plan’s separate account feature constitutes an “accrued benefit” that “may not be decreased by amendment of the plan” under section 204(g)(1). In this case, the transfers at issue resulted in a loss of the separate account feature and thus violated section 204(g)(1). Therefore, plaintiffs have statutory standing. Further, plaintiffs have Article III standing where plaintiffs incurred an injury in fact, and satisfied the causation and redressability requirements. Finally, the court joined the majority of its sister circuits and held that the transferor court’s choice-of-law rules apply when a case has been transferred pursuant to 28 U.S.C. § 1404(a). Here, the court concluded that the statute of limitations cannot serve as a basis for affirming the district court's grant of summary judgment to the Bank. Accordingly, the court reversed and remanded for further proceedings. View "Pender v. Bank of America Corp." on Justia Law