Justia ERISA Opinion Summaries

In this ERISA benefits case, the plan administrator (Appellant) appealed the district court's judgment that a deceased plan participant's stepsons, rather than his siblings, were entitled to the deceased's benefits. Appellant interpreted the term "children" as used in the plan to mean biological or legally adopted children. The Fifth Circuit Court of Appeals reversed, holding that the district court erred when it set aside Appellant's decision and granted judgment for the deceased's stepchildren, as (1) Appellant's interpretation of the term "children" was legally correct; and (2) nothing in the plan or ERISA required Appellant to incorporate the concept of equitable adoption into the plan definition of "children." View "Herring v. Campbell" on Justia Law

The United Automobile, Aerospace, and Agricultural Implement Workers International Union and Local 997 appealed the district court judgment after a five-day bench trial declaring that Whirlpool Corporation may unilaterally modify the health care benefits it provided to retired hourly workers previously employed at the Newton, Iowa manufacturing facilities of Whirlpool's now-dissolved subsidiary, Maytag Corporation. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court correctly found that a case or controversy existed when Whirlpool filed its declaratory judgment action; and (2) the retirees did not have a vested right to the previously granted health benefits under ERISA, as the benefits were provided in a collectively bargained agreement that had no express vesting provision. View "Maytag Corp. v. Int'l Union" on Justia Law

Aschermann suffers from degenerating discs and spondylolisthesis and had lumbar fusion operations in 2002 and 2004. Until 2003 she worked as a sales representative. Back pain left her unable to perform its duties. Between 2003 and 2009 she received disability payments under the employer’s disability plan, a welfare-benefit plan governed by the Employee Retirement Income Security Act. The policy provides that after the first two years of benefits, the question becomes whether the recipient can perform any job in the economy as a whole. Lumbermens stopped paying disability benefits to Aschermann in fall 2009, concluding that she could do sedentary work. The district court held that the decision to end her disability benefits was not arbitrary. The Seventh Circuit affirmed. Aschermann does not deny that her education B.S. in psychology and master’s degree in social work and experience suit her for many desk-bound positions, but claimed inability to work more than four hours a day. The insurer gave notice complying with ERISA, (29 U.S.C. §1133(1), that it wanted new diagnostic test results and other recent information; she was given a “reasonable opportunity” to supplement the file and receive a “full and fair review.” View "Aschermann v. Aetna Life Ins. Co." on Justia Law

Plaintiffs David McCorkle and William Pender appealed a district court order dismissing two of their class action claims against Bank of America Corporation for alleged violations of certain provisions of the Employment Retirement Income Security Act of 1974 (ERISA). Their claims centered on the Bank's use of a normal retirement age (NRA) that allegedly violated ERISA in calculating lump sum distributions and further ran afoul of ERISA's prohibition of "backloading" the calculation of benefit accrual. Upon review, the Fourth Circuit agreed with the district court's conclusion that Plaintiffs failed to state a claim upon which relief could be granted, and it affirmed the district court's judgment to dismiss those claims. View "Pender v. Bank of America Corp." on Justia Law

Aetna Life Insurance Company, as the plan administrator, determined Sharon Wade was no longer disabled and stopped paying long-term disability benefits from Wade's former employer's welfare benefit plan. Wade sought judicial review of Aetna's decision by filing a civil action under ERISA. The district court granted summary judgment in favor of Aetna, concluding that Aetna did not abuse its discretion in terminating Wade's benefits because substantial evidence supported the decision. The Eighth Circuit Court of Appeals affirmed, holding that the district court (1) applied the appropriate standard of review; (2) gave appropriate weight to the Social Security Administration's grant of long-term disability benefits to Wade; and (3) did not abuse its discretion by determining substantial evidence supported Aetna's termination of benefits. View "Wade v. Aetna Life Ins. Co." on Justia Law

In a class action under ERISA, the district court partially decertified the class, 3000 to 3500 members (57 to 71 percent). Plaintiffs appealed under Rule 23(f), which authorizes a court of appeals to “permit an appeal from an order granting or denying class-action certification.” After holding that an order materially altering a previous order granting or denying class certification is within the scope of Rule 23(f), the Seventh Circuit denied the appeal for failure to satisfy the criteria for a Rule 23(f) appeal. View "Matz v. Household Int'l Tax Reduction Inv. Plan" on Justia Law

Plaintiffs, former directory-advertising sales representatives for Idearc were discharged in 2007. Each was older than 40 and each had at least 18 years of service. Idearc claimed they were let go for poor performance; the employees alleged that the terminations were motivated by age discrimination (Age Discrimination in Employment Act, 29 U.S.C. 621) and a desire to negate pension benefits (Employee Retirement Income Security Act, 29 U.S.C. 1140,). They also advanced a retaliation claim. The district court rejected all of their claims. The First Circuit affirmed, noting the company’s performance-based standards. Idearc’s 2002 collective bargaining agreement authorized Idearc to terminate underperforming employees as specified by the plan. Employees were ranked within six-month periods by "percent net gain," calculated by comparing a salesperson's revenues against the revenue produced by his accounts in the previous year. Idearc was permitted to terminate employees failing 4 out of 7 consecutive semesters, but no more than 7.5 percent of a peer group could be terminated in any given semester. View "Cameron v. Idearc Media Corp." on Justia Law

Marantz practiced pulmonary and critical care medicine. In 1997 she underwent surgery for a herniated disc and degenerative disc disease. The surgery did not eliminate her pain. In 1999, she stopped working full time. Through her employment with she received disability coverage from LINA. LINA approved her claim. Additional surgery did not resolve the problem. MRIs revealed degenerative disc disease and spinal stenosis. In 2000 LINA provided funding for Marantz to enroll in an online Masters of Public Health program, for retraining for less-demanding work. In 2001, Marantz began working approximately 20 hours per week for the Illinois Department of Public Health. LINA offset disability benefits and reduced its monthly payment from $7,616 to $5,000 per month. LINA paid benefits for 60 months. In 2004, LINA investigated whether Marantz satisfied the policy’s more stringent definition of disability relevant after the first 60 months: “unable to perform all the material duties of any occupation for which [that worker] may reasonably become qualified based on education, training or experience.” In 2005 LINA terminated benefits, based on a functional capacity evaluation, doctors’ assessments, and surveillance. Marantz sued under the ERISA, 29 U.S.C. 113. The district court entered judgment in the defendants’ favor. The Seventh Circuit affirmed. View "Marantz v. Permanente Med. Grp., Inc." on Justia Law

David Day, an ERISA plan beneficiary, elected to roll over his pension benefits into an individual retirement account (IRA) upon separation from his employer, AT&T. Exercising its discretion, the plan's claims administrator construed Day's lump sum rollover as the equivalent of his having "received" his pension benefits and, according to the terms of AT&T's Disability Income Benefit Plan, reduced Day's long-term disability (LTD) benefits by the amount of the rollover. The district court entered judgment in favor of the plan. The Ninth Circuit Court of Appeals affirmed, holding (1) the administrator reasonably interpreted the plan; (2) AT&T did not breach its fiduciary duties by failing to disclose the possibility that Petitioner's LTD benefits would be reduced by his receipt of pension benefits; and (3) the administrator's actions did not violate the Age Discrimination in Employment Act. View "Day v. AT&T Disability Income Plan" on Justia Law

Plaintiffs participated in UMC’s self-administered retirement contribution plans. UMC provided participants with a variety of investment choices. Plaintiffs elected to locate 100 percent of their investments in the default investment for participants who failed to elect preferred investments. The 2007 Pension Protection Act created “safe harbor relief from fiduciary liability” for plan administrators that directed automatic-enrollment investments into Qualified Default Investment, “capable of meeting a worker’s long-term retirement savings needs.” The regulation grandfathered in stable-value funds that employers used as default investments prior to PPA’s enactment. In 2008, UMC sought to harmonize its practices with new DOL regulation by transferring investments in the prior default fund, the Lincoln Stable Value Fund, into the Lincoln LifeSpan Fund. Because UMC did not have records of which participants chose the fund and which were investors by default, UMC sent notice to all participants with 100 percent in the Fund. Plaintiffs claim that they never received the notice. They suffered financial losses. After exhausting administrative procedures, they sued for breach of fiduciary duty under ERISA. The district court ruled that Lincoln was not a fiduciary under the plan and that UMC was immune from liability under the DOL Safe Harbor regulation. The Sixth Circuit affirmed. View "Bidwell v. Univ. Med. Ctr., Inc." on Justia Law