Justia ERISA Opinion SummariesArticles Posted in Government Law
Md. Ins. Comm’r. v. Kaplan
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
Appeal of A&J Beverage Distribution, Inc.
Respondent A&J Beverage Distribution, Inc. appealed decisions of the Department of Labor (DOL) brought under the Whistleblowers' Protection Act by Petitioner Kevin Perrier. Petitioner worked for A&J as a truck driver. When he first started working, Petitioner did not participate in the company health plan. When premiums increased, Petitioner opted out of the plan. In 2009, rates decreased, and Petitioner claimed he was not informed of the decrease. When he sought information on the plan at that time, the company refused to give it to him. Petitioner notified the company that he had contacted the federal Department of Labor to learn more about his rights under ERISA with regard to notification of the company health plan. A&J then gave Petitioner the requested information, but shortly thereafter, he was terminated. The New Hampshire DOL hearing officer ruled that Petitioner "sustained his burden of proof to show that he was discharged in retaliation for having exercised his legitimate rights under the law." On appeal, A&J asserted preemption: that the whistleblower claim was preempted by ERISA. Upon review, the Supreme Court vacated the DOL's decision: "while the petitioner correctly notes that state and federal courts have concurrent jurisdiction over actions... his whistleblower claim is not such an action. ... [the Court] reject[ed] the petitioner's argument that DOL had jurisdiction over the petitioner's ERISA claim." View "Appeal of A&J Beverage Distribution, Inc. " on Justia Law
Steffens v. BlueCross BlueShield
John Steffens, a beneficiary under an ERISA plan provided by BlueCross, required surgery after an automobile accident. BlueCross paid for a significant portion of Steffens' medical expenses as it was required to do under the Plan. Steffens then sued the other individual in the accident, naming BlueCross as a defendant. Steffens asked for a judgment against BlueCross foreclosing any claim it may have had for subrogation. BlueCross filed a counterclaim against Steffens, alleging it had paid $67,477 on behalf of Stevens and that under the Plan, Steffens was obligated to reimburse BlueCross. The circuit court ordered Steffens to reimburse BlueCross $64,751 plus attorney fees. The court of appeals reversed the circuit court's order and remanded, holding that BlueCross must prove that the surgery-necessitating injuries were related to the accident. The Supreme Court granted review and reversed the judgment of the court of appeals, holding that it was not arbitrary and capricious for the Plan administrator to interpret the Plan and conclude that BlueCross was entitled to reimbursement because the expenses that BlueCross paid arose from an accident for which a third party may have been liable.View "Steffens v. BlueCross BlueShield" on Justia Law