Justia ERISA Opinion Summaries

Bibeau appealed the district court's grant of summary judgment and order directing it, as a related person to a disabled miner's former employer, to pay health insurance premiums, interest, and liquidated damages to the United Mine Workers of America 1992 Benefit Plan. The court concluded that Bibeau's laches claim was precluded under Petrella v. Metro-Goldwyn-Mayer, Inc. because each premium installment gives rise to a separate cause of action for legal relief for which Congress has enacted a statute of limitations to govern timeliness. Further, under the Coal Industry Retiree Health Benefit Act of 1992, 26 U.S.C. 9701-9722, which incorporates the Employee Retirement Income Security Act's (ERISA), 29 U.S.C. 1451(a)(1), enforcement scheme, the district court did not err in awarding interest and liquidated damages. Accordingly, the court affirmed the judgment. View "Holland v. Bibeau Construction Co." on Justia Law

This case arose from injuries suffered by several students during scholastic athletic activities. The students were insured by Central States, an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., employee welfare benefit plan that provides health insurance to participating Teamsters and their dependents. The students were also directly insured by separate accident policies written by Gerber. Central States subsequently filed suit against Gerber, alleging various claims for declaratory judgment and injunctive relief pursuant to federal common law and ERISA section 502(a)(3). The court held that although Central States might well be left without an appropriate remedy as a result of this decision, and that in the future its beneficiaries may be put in the unfortunate position of having to sue their insurance companies to receive benefits to which they are indisputably entitled, the claims raised by Central States are legal, not equitable, and therefore may not be brought under section 502(a)(3). Accordingly, the court affirmed the district court's grant of Gerber's motion to dismiss under Rule 12(b)(6). View "Cent. States, Se. & Sw Areas Health & Welfare Fund v. Gerber Life Ins. Co." on Justia Law

Plaintiff Sonia Graciano was injured after she was hit by a car driven by Saul Ayala. Ayala was insured by defendant California Automobile Insurance Company (CAIC). Three weeks after Graciano's attorney first contacted CAIC regarding the accident, Graciano misidentified both the driver and the applicable insurance policy. CAIC investigated the accident, identified the applicable policy and the correct driver, and offered to settle Graciano's claim with a "full policy limits offer." Graciano did not accept CAIC's full policy limits offer and, in this suit, alleged CAIC and its parent and affiliated companies acted in bad faith, based on an alleged "wrongful failure to settle." Graciano argued CAIC could have and should have earlier discovered the facts, and should have made the full policy limits offer more quickly. The jury found in favor of Graciano and this appeal followed. CAIC argued that, as a matter of law, there was no evidence to support the verdict that CAIC acted in bad faith by unreasonably failing to settle Graciano's claim against Saul. The Court of Appeal agreed, and reversed the judgment. View "Graciano v. Mercury General Corp." on Justia Law

Plaintiffs filed suit against Deputy Arnold and Sheriff Graves, alleging violations of federal and state law after Arnold fatally shot their father while responding to a 911 call that the father was threatening to commit suicide. Plaintiffs also filed suit against ReliaStar to recover $179,000 they allege ReliaStar owes them under the father's accidental death policy. The district court granted Arnold and Grave's motions for summary judgment and granted ReliaStar's motion for summary judgment. The court held that Arnold did not violate the father's Fourth Amendment rights when he entered the father's home without a warrant because he had an objectively reasonable belief that the father would imminently seriously injure himself, and the district court did not err in granting Arnold's motion for summary judgment on the warrantless entry claim because Arnold is entitled to qualified immunity; Arnold is entitled to qualified immunity because he did not violate the father's constitutional right to be free from excessive force; the district court did not err in granting summary judgment for Arnold on the assault and battery claims, the false imprisonment claims, and the intentional infliction of emotional distress claim; the district court correctly granted Graves's motion for summary judgment; and the district court did not err in granting summary judgment for ReliaStar where the record was replete with factual evidence that ReliaStar relied on in determining that the father's death was not accidental, demonstrating that ReliaStar could have reached its determination without resorting to the conflict of interest at issue. Accordingly, the court affirmed the judgment of the district court. View "Rice, et al. v. Reliastar Life Ins. Co." on Justia Law

Nationwide, with 32,000 employees in 49 states, has an ERISA employee-benefits plan that provides short-term disability (STD), long-term disability (LTD), and “Your Time” benefits. An employee can receive Your Time benefits for personal reasons, such as vacation or illness. To receive STD benefits, an employee must be “STD Disabled,” which means “a substantial change in medical or physical condition due to a specific illness that prevents an Eligible Associate from working their current position.” Specific rules govern maternity leave. The first five days of paid maternity leave come out of an associate’s Your Time benefits. Thereafter, a new mother is considered STD Disabled and entitled to STD benefits for six weeks following a vaginal delivery, or eight weeks following a cesarean section. Wisconsin’s Family Medical Leave Act requires that employers allow six weeks of unpaid leave following “[t]he birth of an employee’s natural child[.]” The Act’s “substitution provision” requires employers to allow an employee to substitute “paid or unpaid leave of any other type provided by the employer” for the unpaid leave provided by the statute. A Wisconsin Nationwide employee had a baby. She received six weeks of STD benefits under Nationwide’s plan. She then requested an additional period of STD benefits pursuant to the substitution provision. The plan denied the request, finding that she was no longer short-term disabled under the plan. The Wisconsin Supreme Court had held that, ERISA did not preempt the Wisconsin Act. The district court held that, under the Supremacy Clause, the administrator was required to comply with ERISA rather than the Wisconsin Act. The Sixth Circuit affirmed.View "Sherfel v. Newson" on Justia Law

At issue in this case was the fiduciary implications of a life insurance company’s decision to pay benefits through a retained asset account (RAA) that allows the insurance company to invest the retained assets for its own profit. In Merrimon v. Unum Life Insurance Co., decided also this year, the First Circuit held that an insurer, acting in the place and stead of a plan administrator, properly discharges its duties under ERISA when it pays a death benefit by establishing an RAA as long as that method of payment is called for by the terms of the particular employee welfare benefit plan. In this case, Appellant alleged that an Insurer’s use of RAAs as a method of paying death benefits transgressed its ERISA-inspired fiduciary duties. The district court granted summary judgment in the Insurer’s favor. The First Circuit affirmed largely on the basis of its opinion in Merrimon, holding that, under the circumstances of this case, the Insurer’s choice to pay by means of an RAA did not violate its fiduciary duties. View "Luitgaren v. Sun Life Assurance Co. of Canada " on Justia Law

More than nine years ago, Butler checked into a substance-abuse treatment facility to obtain inpatient rehabilitation for her alcohol addiction. She sought coverage for the treatment through her husband View "Butler v. United Healthcare of TN" on Justia Law

Hayden worked as an office manager at MMI beginning in 1997 and was covered by its long-term disability plan, insured and administered by Liberty and subject to the Employee Retirement Income Security Act, 29 U.S.C. 1001. Hayden suffers from chronic hepatitis C, pancreatitis, fibrocystic breast disease with breast implants, degenerative arthritis, breast carcinoma, hypothyroidism, hypotension, hypertension, and crepitation and decreased range of motion around her shoulders, cervical spine, hips, and knees. She stopped working in January 2010, and applied for benefits under the plan. She also submitted evidence from four doctors detailing general anxiety disorder, major depression, and insomnia. The district court affirmed the denial of benefits on Hayden’s physical-disability claim but remanded her mental-disability claim because the plan administrator failed to consider medical evidence from three doctors. On remand, the plan again rejected Hayden’s claim, and the district court affirmed. The Sixth Circuit affirmed with respect to Hayden’s physical-disability claim but reversed with respect to her mental-disability claim, instructing the district court to award Hayden mental-health benefits consistent with the terms of the plan.View "Hayden v. Martin Marietta Materials, Inc." on Justia Law

As a Solvay employee Moyer participated in Solvay’s ERISA- governed Long Term Disability Plan. In 2005 MetLife initially approved Moyer’s claim for benefits. MetLife reversed its decision in 2007 after determining that Moyer retained the physical capacity to perform work other than his former job. In an administrative appeal, MetLife affirmed the revocation on June 20, 2008. Moyer’s adverse benefit determination letter included notice of the right to judicial review but failed to include notice that a three-year contractual time limit applied. The Summary Plan Description failed to provide notice of either Moyer’s right to judicial review or the applicable time limit. On February 20, 2012, Moyer sued MetLife, seeking recovery of unpaid plan benefits under 29 U.S.C. 1132(a)(1)(B). The district court held that the plan’s limitations period barred Moyer’s claim, noting that the plan documents—which were not sent to participants unless requested—stated that there was a three-year limitations period for filing suit, so that MetLife provided Moyer with constructive notice of the contractual time limit. The Sixth Circuit reversed. Exclusion of the judicial review time limits from the adverse benefit determination letter was inconsistent with ensuring a fair opportunity for review and rendered the letter not in substantial compliance. View "Moyer v. Metropolitan Life Ins. Co" on Justia Law

Plaintiffs, employed by defense contractor Qinetiq to work on a military base in Iraq, were enrolled in Qinetiq’s Basic Long Term Disability, Basic Life, and Accidental Death and Dismemberment insurance policies, governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001, under a single contract with Prudential. Qinetiq paid the premiums. Plaintiffs also purchased, with their own funds, supplemental coverage under the same terms as the basic policies; there was a single summary plan description. An employee would file a single claim for basic and supplemental coverage benefits. The plan booklets provided that loss is not covered if it results from war, or any act of war, declared or undeclared. These exclusions applied to both the basic and supplemental policies. The plaintiffs were not otherwise uninsured for excluded injuries. Qinetiq obtained insurance required by the Defense Base Act, 42 U.S.C. 1651. After Prudential denied claims, the plaintiffs sued, alleging violations of the state consumer fraud acts and the Truth in Consumer Contract, Warranty, and Notice Act; breach of contract and breach of the implied covenant of good faith and fair dealing; and intentional or negligent misrepresentation or omission. They contended that Prudential fraudulently induced them to buy supplemental coverage knowing that any claim they filed would likely be subject to the war exclusions, rendering supplemental coverage effectively worthless. The district court dismissed, treating the basic and supplemental policies as components of a single plan, and holding that all state law claims were preempted by ERISA. The Third Circuit affirmed, holding that the supplemental coverage cannot be “unbundled” from ERISA coverage. View "Menkes v. Prudential Ins. Co. of Am." on Justia Law