Justia ERISA Opinion Summaries

The Hospital filed an interpleader action under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., to resolve competing claims by Barbara Nicholls and Clair Nicholls to certain funds held in the four retirement and pension plans of the late Harold Nicholls. Barbara is Harold's surviving spouse and Claire is Harold's former spouse. The district court granted summary judgment in favor of Claire because the divorce settlement agreement constitutes a qualified domestic relations order (QDRO). The court found that the divorce settlement agreement does not constitute a QDRO because the agreement fails to comply with the requirements of 29 U.S.C. § 1056(d)(3)(C); however, the nunc pro tunc orders constitute valid QDROs that assign funds to Claire from the three retirement and pension plans named in the orders; but because the nunc pro tunc orders do not clearly specify the fourth plan, the orders do not assign funds from that plan to Claire. Accordingly, the court affirmed in part and reversed in part. View "Yale-New Haven Hosp. v. Nicholls" on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., seeking a pension based on permanent disability. On appeal, plaintiff challenged the district court's grant of defendants' motion for summary judgment. The district court granted the motion based on the ground that the Pension Plan gave defendants discretion to determine an applicant's eligibility for pension benefits and that defendants' reliance on SSA determinations, policies, and procedures in this matter was neither arbitrary nor capricious. The court rejected plaintiff's contentions that the real decisionmaker on her benefits applications was the SSA and that the Trustees exercised no discretion but simply rubber-stamped SSA decisions. The court concluded that the district court properly reviewed the Trustees' denial of plaintiff's application under the arbitrary-and-capricious standard. Further, the record also provides no support for plaintiff's contention that the Trustees' denial of her application for a permanent-disability pension was arbitrary and capricious. The court concluded that all of plaintiff's arguments are without merit and the court affirmed the judgment. View "Ocampo v. Building Service 32B-J Pension Fund" on Justia Law

Plaintiff filed suit against AETNA under the civil enforcement provision of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132. AETNA had denied plaintiff's application for continued long-term disability benefits and allowed plaintiff to file an internal appeal within 180 days. The district court dismissed the action for failure to exhaust administrative remedies. The court reversed, holding that because the last day of the appeal period fell on a Saturday, neither that day nor Sunday count in the computation of the 180 days. In this case, because plaintiff mailed his notice of appeal on Monday, it was timely. The court concluded that this method of counting time is widely recognized and furthers the goals and purposes of ERISA. and therefore, the court adopted it as part of ERISA’s federal common law. View "LeGras v. AETNA Life Ins. Co." on Justia Law

Petitioner, the former State director of United Public Workers, AFSCME Local 646, FL-CIO (UPW) and a former administrator of UPW’s Mutual Aid Fund trust (MAF), was held liable by a federal district court for negligently making loans under ERISA and thus breaching his fiduciary duties to the MAF. The court entered judgment against Petitioner in the amount of $850,000. Petitioner filed a complaint in the circuit court requesting that UPW indemnify him for the $850,000 on the grounds that his liability to the MAF arose from actions he took solely in his capacity as agent for UPW and/or that UPW ratified his actions. The circuit court granted summary judgment for UPW. The Intermediate Court of Appeals (ICA) affirmed, concluding that because Petitioner was responsible for his own conduct, he was not entitled to be indemnified for his negligent acts as a matter of law. Petitioner requested certiorari, claiming that the ICA erred in concluding that his negligence claim defeated his indemnification claim as a matter of law. The Supreme Court denied certiorari without reaching this issue, holding that ERISA preemption, not Petitioner’s negligence, defeated Petitioner’s state indemnity claims against UPW as a matter of law. View "Rodrigues v. United Public Workers, AFSCME Local 646" on Justia Law

Orr died in a motorcycle accident. His daughters sought benefits under a group life insurance policy governed by the Employment Retirement Income Security Act and issued by USIC to Orr’s former employer. The policy provided accidental death, subject to exclusions, including one for loss resulting “directly or indirectly from … intoxication[.]” USIC asserted that Orr’s death resulted from his intoxication. The letter explained that autopsy and toxicology reports revealed that Orr’s blood alcohol level at the time of the accident exceeded the legal limit and that USIC’s medical consultant opined that Orr “would have been impaired in attention, coordination, and balance,” as a result. The letter advised the Orrs of their right to seek review and included a copy of USIC’s Life Claims Denial Review Procedure, stating, in boldfaced, all-caps print, that a request for review must be submitted in writing within 60 days and warning: “If … you do not complete both the first and second review before filing a lawsuit, a court can dismiss your lawsuit.“ The document encourages claimants to call with any questions. The Orrs filed suit before completing the review process. The Seventh Circuit affirmed summary judgment in favor of USIC on grounds of failure to exhaust administrative remedies. View "Orr v. Assurant Emp. Benefits" on Justia Law

In 2007, beneficiaries of the Edison 401(k) Savings Plan sued Plan fiduciaries, to recover damages for alleged losses suffered because of alleged breaches of fiduciary duties. The beneficiaries claimed violations with respect to mutual funds added to the Plan in 1999 and mutual funds added to the Plan in 2002, by acted imprudently in offering higher priced retail-class mutual funds as Plan investments when materially identical lower priced institutional-class mutual funds were available. Because ERISA requires a breach of fiduciary duty complaint to be filed no more than six years after “the date of the last action which constitutes a part of the breach or violation” or “in the case of an omission the latest date on which the fiduciary could have cured the breach or violation,” 29 U.S.C. 1113, the district court found the complaint as to the 1999 funds untimely. The Ninth Circuit affirmed, concluding that beneficiaries had not established a change in circumstances that might trigger an obligation to conduct a full due diligence review of the funds within the six-year period. A unanimous Supreme Court vacated. ERISA’s fiduciary duty is derived from the common law of trusts, which provides that a trustee has a continuing duty, separate from the duty to exercise prudence in initially selecting investments, to monitor, and remove imprudent trust investments. So long as a claim alleging breach of the continuing duty of prudence occurred within six years of suit, the claim is timely. The Court remanded for the Ninth Circuit to consider claims that the fiduciaries breached their duties within the relevant 6-year statutory period, considering analogous trust law. View "Tibble v. Edison Int’l" on Justia Law

MetLife appealed the district court's judgment in favor of plaintiff on his claim for pension benefits pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court concluded that MetLife's denial of plaintiff's benefits claim was not arbitrary and capricious where MetLife's rationale for denying plaintiff's claim - that it was impossible to determine whether, or to the extent to which, a FINRA award represented back pay - was not, in fact, unreasonable. The court did not reach MetLife's alternative argument. Accordingly, the court reversed the district court's judgment granting plaintiff relief under ERISA. The court affirmed the denial of plaintiff's request for attorney's fees. View "Roganti v. Metro. Life Ins. Co." on Justia Law

Defendant, a participant in the API Enterprises Employee Benefits Plan, appealed the district court's grant of summary judgment in favor of Humana, API's Plan Manager. Humana filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., against defendant seeking, inter alia, an injunction prohibiting him from disposing of an insurance payout and an "equitable lien to enforce ERISA and the terms of the Plan." The court concluded that the district court erred in determining that Humana is an ERISA fiduciary for two reasons: first, the district court's interpretation of the Plan Management Agreement (PMA) is not persuasive where the district court focused on the subrogation and recovery clause, which do not show that Humana had discretion over the Plan or its assets; and second, even if the court interpreted the PMA to give Humana broad power, the district court failed to explain why Humana is not a ministerial agent. Therefore, the court reversed and remanded for further proceedings. View "Humana Health Plan v. Nguyen" on Justia Law

Insurance companies allegedly refused to honor claims for payment of blood-clotting-factor products. After they paid the claims in full, the district court dismissed a complaint under the Employees Retirement Income Security Act (ERISA) and state law. Following dismissal, both the plaintiffs and defendants sought attorney’s fees and costs. The Third Circuit affirmed denial, but remanded one issue: whether the plaintiffs were entitled to interest on the delayed payment of benefits. On remand, they sought interest of $1.5 to $1.8 million, primarily under the Maryland Code, with $68,000 based on the federal Treasury bill rate. The companies agreed to pay $68,000.00 in interest and the district court dismissed the case. Plaintiffs then sought attorney’s fees and costs of $349,385.15. The district court denied the motion, finding that plaintiffs had failed to achieve “some degree of success on the merits” as required for an award of fees under ERISA. The Third Circuit reversed, holding that the court used an incorrect legal standard to evaluate eligibility for attorney’s fees and misapplied the “Ursic” factors. The “catalyst theory” of recovery is available to the plaintiffs and judicial action is not required under that theory in order to establish some degree of success. View "Templin v. Independence Blue Cross" on Justia Law

Reilly participated in a pension plan offered by Continental, which administers its own defined-benefit plan. The pension depends on the highest average compensation in any 60-month period of employment. “Compensation” includes regular salary, incentive compensation, and deferred compensation deposited in 401(k) plans. Educational bonuses, referral bonuses, overseas allowances, and some other items are not included. When Reilly left Continental’s employ in 1999, he received a statement of qualifying compensation that implied a monthly benefit of about $5,400 starting in 2012, when he would turn 65. In 2012, Continental sent Reilly a different calculation, showing lower compensation and entitlement to $4,200 a month. After internal appeals, Reilly filed suit under the Employee Retirement Income Security Act, 29 U.S.C. 1132(a)(1)(B). The district judge concluded that Continental’s decision was arbitrary and capricious and ordered it to pay monthly benefits of $5,400. The Seventh Circuit reversed. Reilly did not show that $5,400 is the only possible outcome of proper calculation, only that the calculation was improper. By working through the original compensation numbers, the parties may agree what the right pension is. If not, the district court must remand to Continental so that the administrator can make a fresh calculation, which then could be subjected to judicial review. View "Reilly v. Continental Cas. Co." on Justia Law