Justia ERISA Opinion Summaries

Plaintiffs, individual CIGNA Plan participants, filed suit on behalf of themselves and others similarly situated, alleging that CIGNA defendants made misleading communications in regards to the terms of the Plan. Subsequently, on remand, the court concluded that the district court acted within the scope of its discretion in denying CIGNA's motion to decertify the plaintiff class; the district court did not abuse its discretion in determining that the elements of reformation have been satisfied and that the Plan should be reformed to adhere to representations made by the plan administrator; and, in this case, the district court did not abuse its discretion in limiting relief to A+B benefits rather than ordering a return to the terms of CIGNA's original retirement plan. View "Amara v. CIGNA Corp." on Justia Law

In 1997, Appellant began working for Banco Popular de Puerto Rico (BPPR). After Appellant retired in 2009, BPPR made a final calculation of Appellant’s pension, which yielded monthly payments significantly lower than earlier estimates had suggested. Seeking the higher amount he had expected, Appellant brought claims under ERISA, a theory of estoppel, and Puerto Rico contract law. The district court (1) dismissed the ERISA and contract claims, concluding that Appellant failed to state a claim under ERISA and that ERISA preempted the commonwealth claims; and (2) granted summary judgment against Appellant on the estoppel claim, concluding that the unambiguous terms of the benefits plan precluded a claim for estoppel. The First Circuit affirmed, holding (1) Appellant could not recover under ERISA because he could not be awarded relief under the terms of BPPR’s retirement plan; (2) the district court properly held that Appellant’s commonwealth claims “relate to” the ERISA-regulated plan and, accordingly, they were preempted; and (3) because Appellant did not show any ambiguity in the plan, his equitable estoppel claim necessarily failed. View "Guerra-Delgado v. Banco Popular de P.R." on Justia Law

Ibson and her family were insured by UHS through a policy available to her to as a member of her law firm. Due to an error, UHS began informing Ibson’s medical providers that Ibson and her family no longer had insurance coverage. Although UHS eventually paid the claims it should have paid all along, Ibson sued, raising state law claims of breach of contract, negligence, and bad faith, and seeking punitive damages. UHS responded that Ibson’s claims were preempted by the Employee Retirement Income Security Act (ERISA) and barred by the policy’s three-year contractual limitations period. The district court agreed and entered summary. The Eighth Circuit reversed and remanded, agreeing that Ibson’s state law claims are preempted under ERISA, but rejecting entry of summary judgment on the basis of the three-year contractual limitations period. View "Ibson v. United Healthcare Servs., Inc." on Justia Law

Bibeau appealed the district court's grant of summary judgment and order directing it, as a related person to a disabled miner's former employer, to pay health insurance premiums, interest, and liquidated damages to the United Mine Workers of America 1992 Benefit Plan. The court concluded that Bibeau's laches claim was precluded under Petrella v. Metro-Goldwyn-Mayer, Inc. because each premium installment gives rise to a separate cause of action for legal relief for which Congress has enacted a statute of limitations to govern timeliness. Further, under the Coal Industry Retiree Health Benefit Act of 1992, 26 U.S.C. 9701-9722, which incorporates the Employee Retirement Income Security Act's (ERISA), 29 U.S.C. 1451(a)(1), enforcement scheme, the district court did not err in awarding interest and liquidated damages. Accordingly, the court affirmed the judgment. View "Holland v. Bibeau Construction Co." on Justia Law

Plaintiff filed a class action suit against his former employer, Harman, under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., alleging that Harman breached its fiduciary duties by making false and misleading statements to investment firms. On appeal, plaintiff challenged the district court's conversion of defendants' motion to dismiss under Federal Rule of Civil Procedure 12(b)(6)(d) and grant of summary judgment to defendants without giving plaintiff a reasonable opportunity to present evidence. The court did not reach the merits of the appeal, concluding that if the district court violated Rule 12(d), the error would be harmless in this case where discovery would be futile. Accordingly, the court affirmed the judgment. View "Russell v. Harman Int'l Indus." on Justia Law

Plaintiff filed suit against Wells Fargo under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132, alleging that the company improperly terminated her short-term disability benefits while she was undergoing a series of treatments for thyroid disease. The district court found insufficient evidence of disability under the Plan to conclude that Wells Fargo abused its discretion in denying plaintiff's claim. The court held that Wells Fargo failed to meet its statutory and Plan obligations to plaintiff as a beneficiary. By failing to contact plaintiff's psychologist when it was on notice that plaintiff was seeking treatment for mental health conditions and when it had his contact information, as well as properly signed release forms from plaintiff, the plan administrator chose to remain willfully blind to readily available information that may well have confirmed plaintiff's theory of disability. Accordingly, the court reversed and remanded with directions to return the case to Wells Fargo for a full and fair review of plaintiff's claims. View "Harrison v. Wells Fargo Bank, N.A." on Justia Law

Plaintiff filed suit against MetLife, the administrator of a long-term disability insurance plan subject to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., seeking to recover disability benefits. The court concluded that the six-year limitations period began to run on plaintiff's ERISA claim when the cause of action accrues; plaintiff's ERISA complaint in 2012 for benefits from May 1, 1997 forward is time-barred; the court rejected plaintiff's argument that his submission of post-1997 documentation is a new claim for benefits; and MetLife did not waive any defense based on the statute of limitations by failing to specify untimeliness as a basis for denying the claim after its courtesy review. Accordingly, the court affirmed the district court's grant of summary judgment. View "Witt v. Metropolitan Life Insurance Co., et al." on Justia Law

This case arose from injuries suffered by several students during scholastic athletic activities. The students were insured by Central States, an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., employee welfare benefit plan that provides health insurance to participating Teamsters and their dependents. The students were also directly insured by separate accident policies written by Gerber. Central States subsequently filed suit against Gerber, alleging various claims for declaratory judgment and injunctive relief pursuant to federal common law and ERISA section 502(a)(3). The court held that although Central States might well be left without an appropriate remedy as a result of this decision, and that in the future its beneficiaries may be put in the unfortunate position of having to sue their insurance companies to receive benefits to which they are indisputably entitled, the claims raised by Central States are legal, not equitable, and therefore may not be brought under section 502(a)(3). Accordingly, the court affirmed the district court's grant of Gerber's motion to dismiss under Rule 12(b)(6). View "Cent. States, Se. & Sw Areas Health & Welfare Fund v. Gerber Life Ins. Co." on Justia Law

Plaintiff Sonia Graciano was injured after she was hit by a car driven by Saul Ayala. Ayala was insured by defendant California Automobile Insurance Company (CAIC). Three weeks after Graciano's attorney first contacted CAIC regarding the accident, Graciano misidentified both the driver and the applicable insurance policy. CAIC investigated the accident, identified the applicable policy and the correct driver, and offered to settle Graciano's claim with a "full policy limits offer." Graciano did not accept CAIC's full policy limits offer and, in this suit, alleged CAIC and its parent and affiliated companies acted in bad faith, based on an alleged "wrongful failure to settle." Graciano argued CAIC could have and should have earlier discovered the facts, and should have made the full policy limits offer more quickly. The jury found in favor of Graciano and this appeal followed. CAIC argued that, as a matter of law, there was no evidence to support the verdict that CAIC acted in bad faith by unreasonably failing to settle Graciano's claim against Saul. The Court of Appeal agreed, and reversed the judgment. View "Graciano v. Mercury General Corp." on Justia Law

United is the claims administrator for Plans named as defendants in this suit and all of the Plans are governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Spinedex, as assignee and would-be assignee of Plan beneficiaries, filed suit against United and the Plans seeking payment of denied benefit claims. ACS, as well as individual Plan beneficiaries, Jack Adams and Claude Aragon, joined the suit as plaintiffs. The district court granted summary judgment to defendants. The court reversed, concluding that Spinedex had Article III standing; Spinedex was not assigned the right to bring claims for breach of fiduciary duty; ACS does not have associational standing to bring suit against United; Adams' claim for breach of fiduciary duty is time-barred; Spindex's claims as assignee of beneficiaries under the Martz Agency Plan and the Acoustic Technologies Plan are not time-barred; and the anti-assignment provision of the Discount Tire Plan precluded assignment by Plan beneficiaries to Spinedex. The court vacated or reversed, and remanded for further proceedings, the district court's holdings that Aragon's claim for breach of fiduciary duty was not exhausted, that United is not a proper defendant for benefit claims under the American Express Plan, and that some of the claims assigned to Spinedex were not administratively exhausted. View "Spinedex Physical Therapy v. United Healthcare" on Justia Law