Justia ERISA Opinion Summaries

Plaintiff challenged the denial of his claims for long-term disability benefits by defendant, who served as both the administrator of claims and the payor of benefits in the long-term disability plan in which defendant participated. At issue was whether there was a conflict of interest where defendant was both administrator and payor of benefits of the plan governed by ERISA, 29 U.S.C. 1001-1461. The court found that defendant considered the medical information submitted by plaintiff's doctors and relied upon the advice of several independent medical professionals to conclude that plaintiff failed to make a sufficient showing of disability under the plan and, even where plaintiff's own doctors offered different medical opinions than defendant's independent doctors, the plan administrator could give different weight to those opinions without acting arbitrarily or capriciously. Therefore, the court held that a reasonable basis supported defendant's benefits decisions and that the conflict of interest did not render the decisions arbitrary or capricious. View "Blankenship v. Metropolitan Life Ins. Co." on Justia Law

Kurt R. Ward, Attorney at Law, LLC, appealed the district court's order denying its motion for judgment on the pleadings and granting the Plan Parties' (the Bert Bell/Pete Rozelle NFL Player Retirement Plan, the Retirement Board of the Plan, and the Bank of New York Mellon Corporation) cross-motion for judgment on the pleadings. Both parties' motions sought a declaration about whether the Plan Parties had to pay the disability benefits of two of the Ward Firm's retired NFL player clients into the firm's client trust account pursuant to state court jurisdiction for unpaid attorney's fees despite a provision in the Plan prohibiting any "benefit under the Plan" from being assigned or reached by creditors through legal process. The court held that its prior panel precedent held that bargained-for provisions barring assignments in ERISA welfare benefits were valid and enforceable and that the Ward Firm had not directed the court's attention to any such intervening en banc or Supreme Court decision. Accordingly, the court affirmed the judgment and held that the district court did not err in declaring that the spendthrift provision in the Plan prevented the Plan Parties from depositing the disability benefits owned by two retired NFL players into the Ward Firm's trust account. View "Ward v. The Retirement Board of Bert Bell, et al." on Justia Law

A 1998 amendment to the plan effectively penalized lump-sum distributees by voiding their future interest credits, in violation of ERISA, 29 U.S.C. 1054(c)(3). Participants who had received lump sum distributions filed suit in 2007. The district court held that the claims accrued when the plaintiffs received their distributions and that some claims were barred by the six-year state limitations period. The court ordered recalculation of the distributions for the other plaintiffs using a modified version of a method proposed by defendants. The Seventh Circuit reversed in part. The distributions were the final step of a clear repudiation of the participants’ entitlement to anything different and triggered the running of the limitations period; prior communications about the amendment were simply "hints." The plan fiduciaries were not entitled to deference with respect to the recalculation of benefits; the district court must determine how to calculate awards. View "Thompson v. Retirement Plan for SC Johnson" on Justia Law

The court agreed to hear this case en banc in order to reconsider its precedent as to which parties could be sued as defendants in actions for benefits under 29 U.S.C. 1132(a)(1)(B), part of ERISA. Some of the court's previous decisions had indicated that only a benefit plan itself or the plan administrator of a benefit plan covered under ERISA was a proper defendant in a lawsuit under that provision. The court concluded that the statute did not support that limitation, however, and that an entity other than the plan itself or the plan administrator could be sued under that statute in appropriate circumstances. Therefore, the court held that Reliance Standard Ins. Co. was a proper defendant in a lawsuit brought by plaintiff under ERISA and overruled its prior decisions to the contrary. To apply that decision and to resolve other issues raised in the appeal, the court transferred this case back to the three-judge panel to which the case was previously assigned. View "Cyr v. Reliance Standard Life Ins. Co." on Justia Law

The company filed a Chapter 11 bankruptcy petition and continued to make payments to pension plans, as required by collective bargaining agreements. When the company was sold and it no longer employed individuals covered by the plans, the pension fund filed a claim for $5,890,128 (withdrawal liability) and requested that the claim be classified as an administrative expense. The bankruptcy court classified the claim as unsecured debt. The district court reversed and remanded, holding that the portion of withdrawal liability attributable to the post-petition period was entitled to priority. The Third Circuit affirmed. If entire withdrawal liability were automatically classified as a general unsecured claim, it would undercut the purpose of the Multiemployer Pension Plan Amendments Act, 29 U.S.C. 1381, amendment to the Employee Retirement Income Security Act: to secure the finances of pension funds and prevent an employer's withdrawal from negatively affecting the plan and its employee beneficiaries. View "In Re: Marcal Paper Mills, Inc, " on Justia Law

The decedent, killed in a motorcycle accident in 2008, was covered by a life insurance policy, subject to the Employee Retirement Income Security Act, 29 U.S.C. 1101. The insurance company denied a claim by the decedent's widow, claiming that the decedent's anti-coagulant medications contributed to his death so that it fell within an exclusion for medical conditions. The district court concluded that the policy gave the company discretionary authority to determine eligibility and entered summary judgment in the company's favor. The Third Circuit reversed in part and remanded. Deferential review was not appropriate, given the language of the policy. The words "proof of loss satisfactory to Us," surrounded by procedural requirements, do not notify participants that the company has the power to re-define the entire concept of a covered loss on a case-by-case basis. The district court's interpretation of the medical exclusion, in favor of the company, was correct; the clause was not ambiguous. View "Viera v. Life Ins. Co. of N Am." on Justia Law

Defendant appealed from the district court's grant of summary judgment in favor of plaintiff, compelling arbitration of a dispute related to healthcare benefits under an expired collective bargaining agreement. At issue was whether the district court erred in granting plaintiff's motion for summary judgment and issuing an order compelling the arbitration. The court reversed and held that the district court erred in granting summary judgment and compelling arbitration where both parties vigorously disputed issues of both law and fact, including whether the 1994 agreement was ambiguous and whether the summary plan descriptions constituted an intrinsic or extrinsic evidence of the parties' intent. The parties also point to various other extrinsic evidence and vehemently disagree as to whether the bargained for fully-paid health insurance premiums for life or just for the term of the agreement. Under these circumstances, the court held that the question of whether the right to fully-paid premiums vested under the 1994 agreement was best decided in the first instance by the district court and therefore, remanded for further proceedings. View "Newspaper Guild of St. Louis v. St. Louis Post Dispatch, LLC" on Justia Law

Plaintiffs sued defendants, former directors of a retirees association of former unionized transportation workers, alleging, among other things, that defendants breached their fiduciary duty to the retirees association and its members by buying and maintaining a health insurance policy with premiums that far outstripped the benefits received by members. When defendants prevailed on all counts, defendants appealed the district court's denial of their fees motion. At issue was whether the district court erred in denying the fees motion in light of the recent Supreme Court decision, Hardt v. Reliance Standard Life Insurance Co. The court affirmed and held that the district court did not abuse its discretion in denying fees where, although the district court did not have the benefit of Hardt in reaching its decision, nothing in the district court's opinion contradicted Hardt or suggested that the district court would have decided the matter differently in light of Hardt. Accordingly, Hardt did not require the court to reverse or remand. The court also held that, when determining whether attorney's fees should be awarded to defendants, the court focused on whether plaintiffs brought the complaint in good faith. View "Toussaint, et al. v. Mahoney" on Justia Law

Plaintiffs brought an enforcement suit against defendants under the Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. 1001-1461. At issue was whether the district court properly granted summary judgment in favor of defendants, concluding that defendants' practice of offering discounted telephone services to employees and retirees ("Concession") was not a pension plan in whole or in part. The court affirmed summary judgment and held that the district court did not err in holding that Concession was one plan, at least as it regarded to all retirees; in refusing to examine the out-of-region retiree Concession in isolation; in concluding that although Concession did provide income to some retirees, such income was incidental to the benefit, and was not designed for the purpose of paying retirement income; and in holding that Concession did not result in a deferral of income. View "Boos, et al. v. AT&T, Inc., et al." on Justia Law

The Plaintiffs in this action were participants and beneficiaries of a life insurance plan offered by Defendant Qwest Communications International. In 2007, Plaintiffs filed a lawsuit against Qwest, arguing that the Plan made certain changes in violation of ERISA. The district court granted summary judgment in favor of Qwest. Plaintiffs raised seven issues on appeal to the Tenth Circuit, the sum of which was that the Plan misrepresented certain changes that unreasonably impacted employees' retirement benefits. Upon careful consideration of the arguments and applicable legal authority, the Tenth Circuit found that any misrepresentations were not material or in violation of ERISA. The Court affirmed the district court's grant of summary judgment in favor of the Plan.