Justia ERISA Opinion Summaries

Judge, who worked as an airline baggage handler and ramp agent for 20 years, underwent surgery to repair an aortic valve and a dilated ascending aorta. He applied for disability benefits under a group insurance policy issued by MetLife. MetLife denied benefits, finding that Judge was not totally and permanently disabled under the terms of the Plan. After exhausting internal administrative procedures, Judge sued to recover benefits under 29 U.S.C. 1132(a)(1)(B), the Employee Retirement Income Security Act (ERISA). The district court granted judgment on the administrative record in favor of MetLife. The Sixth Circuit affirmed, rejecting arguments that MetLife applied the wrong definition of “total disability,” erred in failing to obtain vocational evidence before concluding that Judge was not totally and permanently disabled, erred in conducting a file review by a nurse in lieu of having Judge undergo independent medical examination, and that there was a conflict of interest because MetLife both evaluates claims and pays benefits under the plan. View "Judge v. Metro. Life Ins. Co." on Justia Law

Tompkins began working in 1978 and was a participant in the Fund, a multi-employer pension fund established and administered under the Employee Retirement Income Security Act, 29 U.S.C. 1001. In 1999, Tompkins was granted a disability pension based on chronic asthmatic bronchitis, which he attributed to working with cement dust for 22 years. Tompkins’s application included agreement to be bound by all the Fund’s rules and regulations, although he did not inquire about those rules or make any effort to find out what they were. Upon receiving his first monthly payment of $2,115.43, he was required to sign a Retirement Declaration that provided notice of disqualifying employment for plan participants receiving retirement pensions but did not include the rules and regulations specific to disability pensioners. In 2007, the Fund suspended his disability pension, claiming that his full-time employment in 2005 and 2006 indicated that he no longer met the definition of “total and permanent disability.” The district court granted summary judgment in favor of the Fund. The Seventh Circuit affirmed. Although the Fund acknowledged ambiguity, it based its decision on a reasonable interpretation. View "Tompkins v. Cent. Laborers' Pension Fund" on Justia Law

Plaintiff left his senior position in 1996, having participated in the Retirement Income Security Plan for Employees (RISPE), a tax-qualified defined benefits plan that guarantees specified retirement benefits, and in the Excess Benefit Plan, a defined unfunded benefits pension plan under which benefits are paid directly by the employer rather than by a trust funded by the employer. Both plans allowed him to choose between an annuity and an actuarial equivalent lump sum distribution. In 2009 he received his RISPE lump sum, $325,054.28 and his Excess Plan lump sum, $218,726.38. The discount rate used to calculate lump sum RISPE benefits was a “segment rate,” 26 U.S.C. 417(e)(3)(C), of 5.24 percent. The discount rate applied to the Excess Plan lump sum was 7.5 percent. The district court rejected his ERISA claim that the discount rate required by both plans was a rate computed by the Pension Benefit Guaranty Corporation on the basis of annuity premiums charged by insurance companies. The Seventh Circuit affirmed. With respect to the RISPE, the accrued benefit, which cannot be reduced retroactively, is the annuity; the lump sum is not the accrued benefit and can be reduced retroactively. The court rejected a conflict-of-interest argument concerning calculation of the Excess Benefit Plan discount rate. View "Dennison v. MONY Life Ret. Income Sec. Plan for Emps." on Justia Law

Plaintiff brought this declaratory judgment action, asserting that the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., preempted a state court order requiring him to turn over benefits received under ERISA retirement and life insurance plans owned by his deceased ex-wife. At issue was whether ERISA prohibited a state court from ordering plaintiff, who had previously waived his right to those benefits, to relinquish them to the administrators of the ex-wife's estate. The court held that ERISA did not preempt post-distribution suits against ERISA beneficiaries because the court detected no conflict with either ERISA's objectives or relevant Supreme Court precedent. Accordingly, the court affirmed the judgment. View "Andochick v. Byrd" on Justia Law

Petitioner Jose Cardoza brought this lawsuit pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), to challenge United of Omaha Life Insurance Company’s calculation of his long-term disability benefits (LTD benefits). United of Omaha answered, asserting its calculation was appropriate, and counterclaimed, demanding that Petitioner reimburse it for payments of short-term disability benefits (STD benefits) which it claimed were miscalculated. On cross-motions, the district court granted Petitioner's motion for summary judgment and denied United of Omaha’s motion, concluding United of Omaha’s decision to calculate Petitioner's LTD benefits and recalculate his STD benefits as it did was arbitrary and capricious. United of Omaha appealed. Upon review, the Tenth Circuit concluded that the district court erred in granting Petitioner's motion for summary judgment with respect to United of Omaha’s LTD benefits calculation: "[t]he plain language of the long-term disability benefits policy instructed United of Omaha to base its calculation of Cardoza’s LTD benefits on his earnings as verified by the premium it received. Thus, United of Omaha’s decision to do so was reasonable and made in good faith." The district court did not err, however, in granting Petitioner's motion for summary judgment with respect to United of Omaha’s recalculation of his STD benefits and demand for reimbursement "United of Omaha’s decision to recalculate Cardoza’s STD benefits based on his earnings verified by premium rather than his actual earnings was not reasonable." The Court therefore reversed in part, affirmed in part, and remanded the case to the district court for further proceedings. View "Cardoza v. United of Omaha Life Insurance" on Justia Law

The Fund, a multi-employer pension plan under ERISA, has a Plan, providing for administration by a Board with authority to make benefit determinations and amend the Plan, including retroactively. No amendment may result in reduced benefits for any participant whose rights have vested, except in specified circumstances. Price began receiving Plan disability benefits under the “Total and Permanent Disability Benefit” category in 1990, after work-related injuries left him unable to work. In 2001, the Fund notified Price that he no longer qualified for benefits under this category, but that he could continue receiving benefits under provisions for “Occupational Disability Benefit.” His benefits were discontinued after 2006, according to an Amendment. Price became eligible for early retirement in 2012. The Board rejected an appeal. The district court granted Price judgment in his suit under ERISA, 29 U.S.C. 1132(a)(1)(B). On remand from the Sixth Circuit, for review determination of vesting under the arbitrary and capricious standard, the judge again ruled in favor of Price. The Sixth Circuit again reversed; the court failed to look to the terms of the plan but instead found that because the Board’s decision letter did not discuss whether the benefits vested, the Board’s decision was arbitrary and capricious. View "Price v. Bd. of Trs. of IN Laborers' Pension Fund" on Justia Law

Plaintiff was a partner in a medical practice where she served as a staff anesthesiologist. When Plaintiff's dependence on opioids came to light, her employer had in force a group employee benefit plan, underwritten and administered by Union Security Insurance Company & Management Company for Merrimack Anesthesia Associates Long Term Disability Plan (USIC), which included long-term disability (LTD) benefits. When Plaintiff applied for those benefits, USIC refused to pay benefits past the point when Plaintiff was discharged from a treatment center, finding that Plaintiff's risk for relapse was not the same as a current disability. Plaintiff brought suit in the federal district court. The district court ultimately awarded Plaintiff LTD benefits for the maximum time available under the plan, concluding that categorically excluding the risk of drug abuse relapse was an unreasonable interpretation of the plan. The First Circuit Court of Appeals affirmed, holding that, in an addiction context, a risk of relapse can be so significant as to constitute a current disability. View "Colby v. Union Sec. Ins. Co." on Justia Law

In this case, participants in the Thunderbird Mining Company Pension Plan sought "shutdown" pension benefits. The PBGC, the government agency that administered pension termination insurance under Title IV of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001-1461, denied the participants' request. These early retirement benefits were triggered by a permanent shutdown of a plant and were payable to plan participants who met certain age and years-of-service requirements. The court held that the agency's determination was not arbitrary or capricious where the record provided sufficient support for the agency's judgment that a permanent shutdown had not occurred before Eveleth's pension plan was terminated on July 24th, 2003. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the agency. View "United Steel, et al. v. Pension Benefit Guaranty Corp." on Justia Law

This appeal arose from a dispute between Unum and the late Kevin Sullivan over long-term disability benefit payments. Sullivan sued Unum, arguing that the termination of his benefits violated the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., and Unum counterclaimed for overpayment of benefits. The court concluded that it was not an abuse of discretion for the administrator to determine that the large payments that Sullivan received in 2004 were payments for the sale of a business for the purpose of calculating his benefits. Unum asserted that the payments were salary, not income. The court reversed the district court's grant of summary judgment and award of attorney's fees, remanding for consideration of Unum's counterclaims. View "Sullivan v. Unum Life Ins. Co., et al" on Justia Law

Plaintiff appealed the district court's grant of summary judgment to the Plan on his claim under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiff asserted that the Plan did not comply with procedures set out by ERISA by changing its basis for denial on administrative appeal and by not identifying the independent physician reviewer who recommended denial on administrative appeal. Because plaintiff did not specify the failure to identify the physician in his amended complaint, the court did not address this issue. The court agreed with plaintiff, however, that the Plan did not substantially comply with ERISA procedures by changing its basis for denying coverage on administrative appeal. The court concluded that remand to the Plan for a full and fair review was appropriate. View "Rossi v. Precision Drilling Oilfield Svcs. Corp. Emp. Benefits Plan" on Justia Law