Justia ERISA Opinion Summaries

Plaintiff, a former employee of defendant, filed this action under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1101 et seq., to challenge the termination of his long-term disability benefits. At issue on appeal was whether the district court erroneously relied on Curtis v. Nevada Bonding Corp. to dismiss the case for lack of subject matter jurisdiction. The court agreed with plaintiff that Vaughn v. Bay Environmental Management, Inc. controlled in these circumstances. Whether plaintiff was a participant for purposes of ERISA was a substantive element of his claim, not a prerequisite for subject matter jurisdiction. Therefore, the court vacated the dismissal and remanded for further proceedings because plaintiff asserted a colorable claim that he was a plan participant and satisfied the threshold for establishing subject matter jurisdiction. View "Leeson v. Transamerica Disability Income Plan" on Justia Law

Plaintiff commenced this action under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., claiming that the administrator of the Principal Life policies had misconstrued the policies in calculating his predisability earnings and that, with a proper calculation, his predisability earnings were far greater. The district court, ruling on cross-motions for summary judgment, entered judgment in favor of Principal Life. The court affirmed. Even though the court recognized that the policy language, defining those expenses that could be subtracted from gross income to arrive at predisability earnings, was somewhat confusing and, to be sure, needlessly verbose, the court concluded that the administrator's interpretation was a reasonable one. View "Fortier v. Principal Life Ins. Co." on Justia Law

Decedent worked for the company from 1982 until 1997, when, at age 52, he was treated for degenerative disc changes, alcohol abuse, and depression. He never returned to work and died in 2008. He was enrolled in his employer's group life, administered by defendant under the Employee Retirement Income Security Act, 29 U.S.C. 1001, was a participant in a long-term disability benefits plan, and had purchased an individual life insurance policy from defendant. He applied for premium waivers under the life insurance policies and received disability benefits under Social Security Disability Insurance and under the employer's plan. Defendant granted a waiver of premiums under the individual policy, but denied a waiver under the group policy. Decedent did not learn about the denial until seven years later. In 2006 and 2008, defendant again denied the application. The estate filed suit in 2010 to recover life insurance benefits and enforce rights under the group policy. The district court granted summary judgment for defendant. The First Circuit reversed, noting defendant's many mistakes in handling the claim and that defendant did not reserve to itself discretion as to interpretation and administration of its plan. Decedent was "totally disabled" for purposes of the plan. View "Scibelli v. Prudential Ins. Co." on Justia Law

Appellant appealed the district court's adverse grant of summary judgment in favor of Standard Insurance in this Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., benefits case. The court held that the Plan administrator did not abuse its considerable discretion in this case where substantial evidence supported the administrator's decision. View "Carrow v. Standard Ins. Co." on Justia Law

Under the Multiemployer Pension Plan Amendments Act of 1980, all "trades or businesses" under "common control" are treated as a single employer for purposes of determining withdrawal liability. 29 U.S.C. 1301(b)(1). SCOFBP incurred withdrawal liability for unfunded pension benefits in 2001 when it ceased operations and paying into a union pension fund. The district court held that the solvent MCRI and MCOF, which were part of a complex set of entities and trusts under control of a single businessman (who went through personal bankruptcy in 1999), were both trades or businesses that were under common control with insolvent SCOFBP at the relevant times, so that both are liable for SCOFBP's withdrawal liability. The Seventh Circuit affirmed, rejecting arguments that MCRI and MCOF were only passive investment vehicles rather than trades or businesses and that the businessman's personal bankruptcy disrupted what had been common control of the three entities. View "Central States SE and SW Areas Pension Plan v. SCOFBP, LLC, " on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)-(3), seeking to recover funds that were erroneously removed from his pension fund account and credited to that of his former wife. The district court entered judgment against the Plan, including the principal amount, accumulated earnings, and pre-judgment interest. On appeal, the Plan argued that enforcement of the judgment was prohibited by the terms of the pension agreement, ERISA's anti-alienation provision, and other provisions of federal and state law. The Plan also argued that the district court's award of accumulated earnings was inconsistent with the court's decision in Dobson v. Hartford Financial Services Group. The court considered all the Plan's arguments and found that none of them warranted reversal of the district court's judgment that the Plan must pay plaintiff what he was due, whether or not it could succeed in recovering the funds that it, through no fault of plaintiff's, erroneously paid to his former wife. View "Milgrim v. Orthopedic Assoc. Defined Contribution Pension Plan" on Justia Law

Plaintiff, an RN, stopped working at the hospital and went on disability only a few months after starting work. Her symptoms were attributed to chronic pancreatitis, chronic pain syndrome or fibromyalgia; she took "impressive amounts of narcotics" to manage her pain, which caused negative side effects. After about five years, the company terminated benefits, finding that she was not totally disabled, as defined by the policy. The district court upheld the termination in a suit under the Employee Retirement Income Security Act, 29 U.S.C. 1132(a)(1)(B). The First Circuit remanded for further review, reasoning that plaintiff's activities, shown on surveillance tapes, and the lack of clinical documentation were overstated.View "Maher v. MA Gen. Hosp." on Justia Law

The former trustees of the Plasterers' Local Union No. 96 Pension Plan appealed from the judgment of the district court in favor of the current trustees of the Plan. The district court's judgment was based on its finding that the former trustees breached their fiduciary duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., regarding the investment Plan assets set forth under 29 U.S.C. 1104(a)(1)(B) and (C). On appeal, the former trustees challenged the district court's determination as to liability, its method of calculating damages, and the award of attorney fees. The court concluded that the district court erred as to each of these issues and therefore vacated the judgment and remanded the case for further proceedings. View "Plasterer's Local Union No. 96 v. Pepper" on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)-(3), seeking to recover funds that were erroneously removed from his pension fund account and credited to that of his former wife. The district court entered judgment against defendant in the amount of $1,571,723.73, which included the principal amount, accumulated earnings and pre-judgment interest. On appeal, defendant argued that enforcement of the judgment was prohibited by the terms of the pension agreement, ERISA's anti-alienation provision, and other provisions of federal and state law. Defendant also argued that the district court's award of accumulated earnings was inconsistent with the court's decision in Dobson v. Hartford Financial Services Group, Inc. Applying the appropriate standards of review, the court found defendant's arguments were without merit and affirmed the judgment of the district court. View "Milgrim v. Orthopedic Assoc." on Justia Law

After defendant was in a serious automobile accident, a benefit plan administered by plaintiff paid $66,866 for his medical expenses. Defendant then recovered $110,000 from third parties, with the assistance of counsel. Plaintiff, which had not sought to enforce its subrogation rights, demanded reimbursement of the entire $66,866 it had paid without allowance for legal costs, which had reduced defendant's net recovery to less than the amount it demanded. Plaintiff sued for "appropriate equitable relief" pursuant to the Employee Retirement Income Security Act, 29 U.S.C. 1132(a)(3) B). The district court ordered plaintiff to pay the entire. $66,866. The Third Circuit vacated, holding that defendant may assert equitable limitations, such as unjust enrichment, on plaintiff's equitable claim. View "US Airways, Inc v. McCutchen" on Justia Law