Justia ERISA Opinion Summaries

Plaintiff appealed from the district court's dismissal of his claim for benefits under ERISA, 29 U.S.C. 1001 et seq., where the district court held that he failed to exhaust his administrative remedies. The court held that because plaintiff sought either current or future benefits, the plan provided an administrative procedure for his claim. The facts alleged in plaintiff's complaint showed neither futility nor the lack of an administrative remedy and therefore, the court concluded that he was required to exhaust his administrative remedies under the plan before he could bring a civil action in federal court. View "Angevine v. Anheuser-Busch Co. Pension Plan, et al." on Justia Law

After defendant denied plaintiff's claim for long-term disability benefits (LTD benefits), where plaintiff suffered from fibromyalgia, plaintiff filed a complaint against defendant pursuant to ERISA, 29 U.S.C. 1000 et seq. At issue was whether the district court properly granted summary judgment in plaintiff's favor finding that defendant had abused its discretion in denying benefits to plaintiff. The court held that the district court improperly determined that defendant abused its discretion when it ultimately denied the LTD benefits claim. Based on the record, there was more than a scintilla of evidence supporting defendant's conclusion that plaintiff's condition did not render him "disabled" under the policy's any occupation definition and defendant's decision was supported by substantial evidence, where a reasonable person could have reached a similar decision. The court also held that the fact that defendant operated under a structural conflict of interest, as both plan administrator and insurer, did not warrant a finding that defendant abused its discretion in denying plaintiff's claim. Accordingly, the court reversed summary judgment and remanded for further proceedings. View "Green v. Union Security Ins. Co." on Justia Law

Appellant, the named beneficiary of an accident benefits plan that her husband obtained through his employer, brought suit under ERISA, 29 U.S.C. 1001 et seq., alleging that the plan administrator, Metropolitan Life Insurance (Metlife), abused its discretion in determining that her husband was intoxicated at the time of the accident and denying coverage. At issue was whether the district court properly granted summary judgment to Metlife because Metlife's interpretation of the relevant policies was arbitrary and capricious and not supported by substantial evidence. The court held that Metlife did not abuse its discretion as plan administrator when it denied benefits based on the general exclusion for intoxication that appeared in the certificate of insurance. The court also held that the toxicology report, which concluded that the husband's blood alcohol level was above the state limit, constituted evidence that a reasonable mind might accept as adequate to support a conclusion and therefore, satisfied the substantial evidence standard. The court also held that because it agreed with the district court's conclusion that the denial of benefits was justified in light of the intoxication conclusion, it need not address Metlife's assertion that the husband's death was not accidental because it was reasonably foreseeable or, alternatively, the result of intentional self-inflicted injury. Accordingly, summary judgment was affirmed. View "River v. Edward D. Jones Co., et al." on Justia Law

Plaintiff worked as a sales representative when she became disabled and sought long-term disability benefits under the company's ERISA plan (“the Plan”) after a series of back surgeries. In her suit under 29 U.S.C.1132(a)(1)(B) the district court held that she was ineligible for benefits after the first 24 months; the Seventh Circuit remanded. Having not heard from the Plan for almost five months, plaintiff again filed suit under ERISA, claiming that silence constituted a deemed denial of her benefit claim. A little over a month later, the Plan informed her that it would pay the benefits, moved to dismiss the case as moot. The district court denied the motion, issued a judgment against the Plan for the exact amount it had agreed to pay, and denied plaintiff's motion for fees. The Seventh Circuit vacated the grant of summary judgment on the benefit claim, which was moot, and affirmed denial of fees. The district court had jurisdiction over the fee claim, but the plaintiff did not adequately substantiate her request.View "Pakovich v. Verizon LTD Plan" on Justia Law

Appellant appealed the district court's summary judgment on her ERISA, 29 U.S.C. 1132(a)(1)(B), claim to recover denied health care benefits and the magistrate judge's decision to limit discovery. At issue was the scope of admissible evidence and permissible discovery in an ERISA action to recover benefits under section 1132(a)(1)(B). The court held that the district court too narrowly defined the scope of discovery where appellant sought to discover evidence that would indicate whether the administrative record was complete, whether Blue Cross complied with ERISA's procedural requirements, and whether Blue Cross previously afforded coverage claims related to the jaw, teeth, or mouth. The court concluded that appellant's discovery request was at least reasonably calculated to lead to the discovery of some admissible evidence and that the district court's abuse of discretion prejudiced appellant's ability to demonstrate that Blue Cross failed to comply with ERISA's procedural requirements. Accordingly, the court vacated and remanded for further proceedings. View "Crosby v. Louisiana Health Serv." on Justia Law

Appellants filed suit against nine pilots and their spouses asserting claims for equitable relief under 29 U.S.C. 1132(a)(3) of ERISA where appellants alleged that the pilots and their spouses obtained "sham" divorces for the purpose of obtaining lump sum pension distributions from the Continental Pilots Retirement Plan. At issue was whether ERISA, 29 U.S.C. 1056(d)(1), allowed a retirement plan administrator to seek restitution of benefits that were paid to a plan participant's ex-spouse pursuant to a domestic relations order such as a divorce decree, if the administrator subsequently determined that the domestic relations order was based on a "sham" divorce. The court agreed with the district court's holding that subsection 1056(d)(3)(D)(i) did not authorize an administrator to consider or investigate the subjective intentions or good faith underlying a divorce. Therefore, the court affirmed the district court's dismissal of appellants' claims. View "Brown, et al v. Continental Airlines, Inc., et al." on Justia Law

After injuring her back in a car accident, plaintiff filed for and received long-term disability benefits from the insurance plan sponsored by her employer. Plaintiff brought suit pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), 42 U.S. C. 29 U.S.C. 1001 et seq., against her employer and the administrators and underwriters of her employer-sponsored long-term benefit disability insurance policy after the claims administrator of that plan determined that she no longer qualified for benefits. At issue was whether the district court properly granted defendants' motion for summary judgment, finding no violation of law. The court held that because defendants acted reasonably, the court concluded that defendants' termination of plaintiff's benefits complied with federal law. The court found none of plaintiff's procedural claims persuasive and held that the district court did not err when it held that defendants did not violate plaintiff's right to a full and fair review of her adverse eligibility determination. The court also rejected plaintiff's argument that the district court violated local rule 7(h) where plaintiff failed to make this argument before the district court. Accordingly, the court affirmed the judgment of the district court. View "Pettaway v. Teachers Ins. and Annuity, et al." on Justia Law

The company closed paper mills and eliminated a health-care subsidy for retirees. The union filed suit in Ohio under the Labor Management Relations Act, 29 U.S.C. 185, and the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132. The company filed a declaratory judgment suit in Wisconsin; the district court dismissed for lack of jurisdiction. The Seventh Circuit vacated and remanded. Although the suit does not seek equitable relief as described in Sect. 502 of ERISA, Sect. 2201 does authorize declaratory relief. The court further reasoned that the district court acknowledged its jurisdiction over the LMRA suit and that the union's suit came within the 502 grant of jurisdiction, so this mirror-image suit by the plan’s sponsor also is within federal subject-matter jurisdiction. In dismissing the Wisconsin litigation, the district judge assumed that the controversy would be resolved in Ohio. That is no longer true because the union mistakenly named a parent company that was not a party to the collective bargaining agreements; the case has been dismissed. View "NewPage Wis. Sys., Inc., v. United Steel, Paper & Forestry, Rubber, Mfg,. Energy Allied Indus. & Servs. Workers Int'l Union" on Justia Law

This case stemmed from the collective bargaining agreement (CBA) between Volvo Group North America, LLC (Volvo) and the union representing workers at Volvo's New River Valley assembly plant (NRV). At issue was whether the CBA permitted Volvo to make unilateral changes to the health benefits of retirees from its NRV assembly plant after the agreement expired. The court held that Volvo was not permitted to make unilateral modifications to the retirees' health benefits after the expiration of the CBA unless it followed the mechanism agreed to by both parties in that agreement. Therefore, the court affirmed the judgment of the district court where Volvo could not employ that mechanism in this case. View "Quesenberry, et al. v. Volvo Trucks North America Retiree Healthcare Benefit Plan, et al." on Justia Law

Plaintiff filed an action against defendants (collectively, the Plan) for refusing to pay certain long-term disability benefits. At issue was whether the district court erred in granting summary judgment for defendants and dismissed plaintiff's claims without prejudice due to his failure to exhaust available administrative remedies under the Plan. The court held that the district court adopted the Plan's reading of ERISA, 29 C.F.R. 250.503-1(i) without the benefit of the Secretary of Labor's interpretation of that provision. Therefore, deferring to the Secretary's plausible approach, the court held that where a claimant sought review of his or her disability claims, the quarterly meeting rule was restricted to multiemployer plans. Accordingly, the Plan was required to render a decision within 90 days of plaintiff's administrative appeal and failed to do so. Consequently, plaintiff's claims must be deemed exhausted and the judgment was reversed and remanded. View "Barboza v. CA Assoc. of Prof'l Firefighters, et al." on Justia Law