Justia ERISA Opinion Summaries

These consolidated appeals arose from a class action against ABB under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. The district court entered judgment against the ABB defendants and the Fidelity defendants for breaching their fiduciary duties in violation of sections 1104, 1106, and 1109. The court affirmed the district court's judgment and award against the ABB fiduciaries with respect to recordkeeping; vacated the judgment and award on the participants' investment selection where the district court erroneously substituted its own de novo interpretation of the Plan, and mapping claims where the claims were timely; reversed the judgment against Fidelity where the district court erred in finding that Fidelity breached its fiduciary duty of loyalty by paying the expenses on the float accounts and distributing the remaining float to the investment options; vacated the attorney fee award as to all defendants; and remanded for further proceedings. View "Tussey, et al. v. ABB, Inc., et al." on Justia Law

CareFirst, Inc., a nonstock, nonprofit Maryland corporation, is a holding company with two subsidiaries that provides health insurance for millions of Maryland residents. State law confers broad authority on the Maryland Insurance Commissioner to oversee its operation and adherence to its mission. This case arose from the termination of Leon Kaplan, a former executive of CareFirst. CareFirst declined to pay part of the post-termination compensation set forth in Kaplan's employment contract, reasoning that the compensation was not for "work actually performed," as that standard had been interpreted by the Commissioner. The Commissioner affirmed the decision not to pay the benefits, concluding that the payments would violate Md. Code Ann. Ins. 14-139. The Court of Appeals affirmed, holding (1) the Commissioner's determination was not preempted by ERISA; (2) the Commissioner's construction of the insurance code was legally correct; and (3) there was substantial evidence to support the Commissioner's determination in this case.View "Md. Ins. Comm'r. v. Kaplan" on Justia Law

Lewis was injured in an automobile accident and her health plan paid $180,000 for her medical treatment Lewis filed a tort suit against the driver (her son-in-law), represented by Georgia lawyer Lashgari, and obtained a $500,000 settlement. Lashgari knew the plan had a subrogation lien, but split the proceeds between himself and Lewis. He claimed that the plan was owed nothing. The plan filed suit under ERISA to enforce the lien, 29 U.S.C. 1132(a)(3). The defendants argued that because the settlement funds have been dissipated, the suit was actually for damages, not authorized by ERISA. The district judge ordered the defendants to place $180,000 in Lashgari’s trust account pending judgment. The defendants did not comply. A year later, the defendants having neither placed any money in a trust account nor produced any evidence of their inability to pay, the judge held them in civil contempt, ordered them to produce records that would establish their financial situations, and ordered Lashgari to documents relating to the contempt to the General Counsel of the State Bar for possible disciplinary proceedings against him. The defendants appealed the contempt order. The Seventh Circuit dismissed, characterizing the appeal as frivolous and the defendants’ conduct as outrageous. View "Cent. States, SE & SW Areas Health & Welfare Fund v. Lewis" on Justia Law

Union-affiliated benefit funds (collectively, the Fund) sued Employer to recover unpaid employee-related remittances allegedly due under a collective bargaining agreement (CBA). The Fund also sought attorneys’ fees and costs pursuant to both the CBA and ERISA. The district judge awarded the Fund $26,897 in damages, and, in a separate judgment, awarded $18,000 in attorneys’ fees and $16,688 in expenses. Both parties appealed. The First Circuit Court of Appeals reversed the district court’s determination of damages, but the Supreme Court reversed, concluding that the First Circuit lacked jurisdiction to review the damage judgment. On remand, the First Circuit reinstated the cross-appeals challenging the separate judgment for fees and costs and affirmed the district court’s order awarding attorneys’ fees and expenses, holding that the award was not an abuse of the judge’s discretion. View "Int’l Union v. Ray Haluch Gravel Co." on Justia Law

In 2004, plaintiff appealed the denial of his long term disability (LTD) benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Liberty moved for summary judgment. In a 2009 Report and Recommendation (R&R), the magistrate judge recommended denying Liberty's motion and granting summary judgment sua sponte to plaintiff. In 2012, the district court adopted the R&R and entered summary judgment for plaintiff, but denied his request for attorneys' fees. The court concluded that the district court did not err in granting summary judgment on plaintiff's claim for LTD benefits because Liberty's denial of LTD benefits was arbitrary and capricious where Liberty ignored substantial evidence from plaintiff's treating physician that he was incapable of performing his current occupation, while failing to offer any reliable evidence to the contrary; the court retained discretion to consider the Chambless v. Masters, Mates & Pilots Pension Plan factors, in determining whether to grant an eligible plaintiff's request for attorneys' fees, but must do so in a manner consistent with the court's case law, and could not selectively consider some factors while ignoring others; the district court misapplied the Chambliss framework, and therefore erred, in denying fees to a prevailing plaintiff primarily on the conclusion that Liberty had not acted in bad faith; and the record revealed no particular justification for denying plaintiff's attorneys' fees, and awarding fees in the circumstances presented here furthered the policy interest in vindicating the rights secured by ERISA. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Donachie v. Liberty Mutual Ins. Co., et al." on Justia Law

Plaintiff, who worked for Metropolitan Life Insurance Co. (“MetLife”), made a claim for long-term disability benefits (LTD). In 2005, the claim was approved. That same year, MetLife denied Plaintiff’s assertion that he was entitled to a larger payment calculation. In 2012, Plaintiff filed suit against MetLife under the Employee Retirement Income Security Act of 1974 (ERISA), claiming that MetLife had been underpaying his monthly benefits since 2005. The district court granted MetLife’s motion for summary judgment, concluding that Plaintiff’s suit was barred by the six-year statute of limitations. The First Circuit Court of Appeals affirmed, thus rejecting Plaintiff’s theory that the LTD plan must be analogized to an installment plan so as to alter the accrual date of his claim, holding that Plaintiff’s claim against MetLife was barred by the statute of limitations. View "Riley v. Metro. Life Ins." on Justia Law

The employers were formerly contributing members of the Teamsters Local Union No. 293 Pension Plan. In 2007-2008 each employer reached an agreement with the Plan to terminate its membership. They were required to pay, and have paid, “withdrawal liability” reflecting each employer’s share of unfunded, vested pension benefits under the Multiemployer Pension Plan Amendments Act, 29 U.S.C. 1381–1461. Under the Act, if the plan is terminated altogether by a “mass withdrawal” of the remaining members within three years, the earlier withdrawing members may be subject to additional “reallocation liability.” Disputes about the amount of such reallocation liability are subject to mandatory arbitration. The employers claim that a 2009 mass withdrawal was expedited to occur within the three-year period in order that they would be subject to reallocation liability. The Plan trustees sought more than $12 million in additional funds from the employers. The district court dismissed their suit for failure to complete arbitration. The Sixth Circuit affirmed. The Act requires that the claim of “sham” mass withdrawal be arbitrated. View "Knall Beverage, Inc. v. Teamsters Local Union No. 293 Pension Plan" on Justia Law

Plaintiffs filed suit alleging violations of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs claimed that the bonds that they invested in were an unsuitable investment for the Plans' funds and that defendant made multiple oral misrepresentations to plaintiffs in violation of his fiduciary duties. The district court ruled that there was a disputed issue of material fact as to whether defendant was an ERISA fiduciary, but nonetheless granted summary judgment because defendant provided plaintiffs with written disclosures. The court concluded that defendant did not qualify as a fiduciary under ERISA subsection 1002(21)(A)(i) because he did not exercise discretionary authority or control over the investment at issue; subsection 1002(21)(A)(ii) because he did not receive a fee from the Plans in connection with the investment; and section 1002(21)(A)(iii) because it was inapplicable in this instance. Accordingly, the court affirmed the judgment of the district court. View "Tiblier, et al. v. Dlabal, et al." on Justia Law

Plaintiff appealed the Rule 12(b)(1) dismissal of her putative class action complaint brought under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court concluded that, based on the record to date and at this Rule 12(b)(6) juncture, the district court erred in finding that the three-year limitations period applied to plaintiff's claims in Count 2. The court concluded, however, that plaintiff's claims in Count 2 were time-barred by ERISA's six-year period of limitations. Accordingly, the court affirmed the judgment of the district court. View "Fuller v. SunTrust Banks, Inc., et al." on Justia Law

Dr. Charles Dahl and Ms. Kim Dahl divorced in 2010. Ms. Dahl filed suit in the United States District Court for the District of Utah, alleging federal-law and state-law claims stemming from the terms of the divorce: (1) that Dr. Dahl improperly administered the pension trust of his medical practice to deny her funds and an accounting and (2) that her telephone conversations with the Dahls’ minor children were unlawfully monitored, recorded, and disclosed by Dr. Dahl, his attorney, and the children’s guardian ad litem (GAL) in the divorce proceedings. The district court dismissed the federal-law pension claims for lack of subject-matter jurisdiction and granted summary judgment against Ms. Dahl on the federal-law wiretapping claims. It then declined to exercise jurisdiction on the state-law claims. Ms. Dahl appealed. Upon review, the Tenth Circuit: affirmed the district court’s dismissal of Ms. Dahl’s pension claims on the ground that the pension trust did not qualify as an employee benefit plan under ERISA, but that the claim should have been on the merits rather than for lack of jurisdiction. The Court affirmed the district court in all other respects. View "Dahl v. Dahl, et al" on Justia Law