Justia ERISA Opinion Summaries

Plaintiffs filed suit alleging that DHL's decision to eliminate plaintiffs' right to transfer their account balances from DHL's defined contribution plan to its defined benefit plan violated the "anti-cutback" rule of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1054(g), which prohibits any amendment of an employee benefits plan that would reduce a participant's "accrued benefit." The court, agreeing with the First Circuit and the district court, concluded that DHL's 2004 plan amendment did not, as a matter of law, violate the anti-cutback rule. The reduction of periodic benefits paid from the Retirement Income Plan that resulted from DHL's elimination of the transfer option did not violate section 1054(g)(1) where the accrued benefits of both the defined contribution and the defined benefit plan remained intact. The court further concluded that the 2004 amendment did not violate the anti-cutback rule as a matter of law where this case fits within the regulatory exception for elimination of an "optional form of benefit," even if the transfer option was such a benefit. Accordingly, the court affirmed the judgment of the district court. View "Andersen v. DHL Retirement Pension Plan" on Justia Law

Two trustees of the Fund filed suit under section 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. 185(a), and section 515 of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1145, to collect unpaid benefit contributions allegedly owed by Goebel. On appeal, the Trustees challenged the dismissal of the ERISA claim. The court read the Trust Agreement to unambiguously require that an employee is actually represented by the Union at the time the Fund claims delinquent contributions were owed on behalf of that employee. As it is undisputed that the Union did not "represent" the employees at the times in question, the Trustees failed to demonstrate the Fund was entitled to the contributions they seek under the terms of the Trust Agreement. Accordingly, the court affirmed the district court's grant of summary judgment to Goebel. View "Kern, et al. v. Goebel Fixture Co." on Justia Law

At issue in this case was the fiduciary implications of a life insurance company’s decision to pay benefits through a retained asset account (RAA) that allows the insurance company to invest the retained assets for its own profit. In Merrimon v. Unum Life Insurance Co., decided also this year, the First Circuit held that an insurer, acting in the place and stead of a plan administrator, properly discharges its duties under ERISA when it pays a death benefit by establishing an RAA as long as that method of payment is called for by the terms of the particular employee welfare benefit plan. In this case, Appellant alleged that an Insurer’s use of RAAs as a method of paying death benefits transgressed its ERISA-inspired fiduciary duties. The district court granted summary judgment in the Insurer’s favor. The First Circuit affirmed largely on the basis of its opinion in Merrimon, holding that, under the circumstances of this case, the Insurer’s choice to pay by means of an RAA did not violate its fiduciary duties. View "Luitgaren v. Sun Life Assurance Co. of Canada " on Justia Law

More than nine years ago, Butler checked into a substance-abuse treatment facility to obtain inpatient rehabilitation for her alcohol addiction. She sought coverage for the treatment through her husband View "Butler v. United Healthcare of TN" on Justia Law

PSH filed suit against the Wells Fargo & Company Health Plan, governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., and UBH, seeking payment for additional days of inpatient treatment for an employee with severe anorexia nervosa. UBH is a third-party claims administrator of the Plan and UBH refused to pay for more than three weeks of inpatient hospital treatment for the employee. The court concluded that UBH did not follow procedures appropriate to the employee's case; materials outside the administrative record should have been considered by the district court in any review of UBH's benefits denial; and, even conducting an abuse of discretion review uninfluenced by any procedural irregularity or conflict of interest - and considering only the record that UBH had before it when it made its benefits determination - the court held that UBH improperly denied benefits to the employee. The court concluded that UBH improperly denied benefits under the Plan in violation of its fiduciary duty under ERISA. Accordingly, the court reversed the district court's judgment holding otherwise. View "Pacific Shores Hospital v. UBH" on Justia Law

Hayden worked as an office manager at MMI beginning in 1997 and was covered by its long-term disability plan, insured and administered by Liberty and subject to the Employee Retirement Income Security Act, 29 U.S.C. 1001. Hayden suffers from chronic hepatitis C, pancreatitis, fibrocystic breast disease with breast implants, degenerative arthritis, breast carcinoma, hypothyroidism, hypotension, hypertension, and crepitation and decreased range of motion around her shoulders, cervical spine, hips, and knees. She stopped working in January 2010, and applied for benefits under the plan. She also submitted evidence from four doctors detailing general anxiety disorder, major depression, and insomnia. The district court affirmed the denial of benefits on Hayden’s physical-disability claim but remanded her mental-disability claim because the plan administrator failed to consider medical evidence from three doctors. On remand, the plan again rejected Hayden’s claim, and the district court affirmed. The Sixth Circuit affirmed with respect to Hayden’s physical-disability claim but reversed with respect to her mental-disability claim, instructing the district court to award Hayden mental-health benefits consistent with the terms of the plan.View "Hayden v. Martin Marietta Materials, Inc." on Justia Law

In a previous decision of an appeal of a case brought under the Employees Retirement Income Security Act of 1974, the First Circuit Court of Appeals agreed with Plaintiff that the First Circuit should not longer apply the arbitrary and capricious standard of review to certain benefits actions. Because the Court found the record was inadequate to permit de novo review on Plaintiff’s entitlement to benefits, the Court remanded the case for further development of the evidence. Plaintiff subsequently filed a motion seeking an award of attorney’s fees and costs for the litigation in the district court and on appeal. The First Circuit remitted Plaintiff’s fee request to the district court for a determination in the first instance of the proper amount of the award, holding (1) the Court’s prior decision afforded Plaintiff a degree of success on the merits that qualified her for an award of fees; and (2) an award of fees is appropriate and properly ordered at this time. View "Gross v. Sun Life Assurance Co. of Canada" on Justia Law

DiGeronimo and other employers contributed to the Teamsters Local Union No. 293 Pension Plan, which is governed by the Employee Retirement Income Security Act, 29 U.S.C. 1001–1461. Defendants are trustees of the Plan and managed the Plan, including negotiating and ratifying contribution rates and overseeing the Plan’s investments and expenses. Defendants terminated the Plan in December 2009 because substantially all of the Plan’s contributing employers withdrew from paying contributions. Defendants assessed $1,755,733 in “withdrawal liability” to DiGeronimo, which represents its share of the $49,000,000 in unfunded, vested benefits that the contributing employers owed the Plan. DiGeronimo sued defendants under 29 U.S.C. 1451(a), alleging that defendants negligently managed the Plan’s assets, causing increased withdrawal liability. The district court dismissed holding, that there was no substantive basis for the negligence claim in any section of ERISA or under the federal common law. The Sixth Circuit affirmed: a contributing employer to a multiemployer pension plan has no cause of action against plan trustees for negligent management under the federal common law of ERISA pension plans. View "DiGeronimo Aggregates, LLC v. Zemla" on Justia Law

Plaintiff Lucrecia Carpio Holmes appealed a district court’s ruling that her claim for disability benefits under the Employee Retirement Income Security Act (ERISA) was barred due to her failure to exhaust administrative remedies. Finding no reversible error, the Tenth Circuit affirmed. View "Holmes v. Colorado Coalition" on Justia Law

Plaintiff filed suit against his deceased son's employer and the insurer, MetLife, under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq, after plaintiff was denied benefits of the son's life insurance policy. The court reversed the district court's grant of summary judgment to defendants on plaintiff's section 1132(a)(1)(B) claim where there were outstanding questions of material fact regarding whether MetLife abused its discretion when it denied benefits because the plan did not define evidence of insurability; reversed the denial of plaintiff's motion to add a claim under section 1132(a)(3); and remanded to the district court so that plaintiff has a full opportunity to litigate both his ERISA claims. View "Silva v. Metropolitan Life Ins. Co., et al." on Justia Law