Justia ERISA Opinion Summaries

An employee of MITRE Corporation, serving as a Principal Business Process Engineer, contracted COVID-19 twice. After experiencing long-COVID symptoms that prevented her from returning to her occupation, she applied for long-term disability (LTD) benefits under her employer’s ERISA-governed plan, administered by Reliance Standard Life Insurance Company. Reliance denied her claim, asserting she was not “Totally Disabled.” She submitted further medical documentation and filed an internal appeal. The plan and ERISA regulations required Reliance to respond within 45 days, extendable by another 45 days only for “special circumstances,” with written notice specifying the reason and expected decision date.Reliance took more than 45 days to issue a decision, did not specify a date for resolution, and cited only routine medical review as justification for delay. The employee sued in the United States District Court for the Eastern District of Virginia after Reliance failed to timely decide her appeal. The district court found that Reliance had not complied with ERISA’s timing and notice requirements, held that de novo review (rather than deferential review) was appropriate, and ruled in favor of the employee, awarding LTD benefits and interest.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether Reliance’s delay deprived it of deferential review of its benefit determination. The court held that, because Reliance failed to decide the internal appeal within the required time and had not justified its delay with a special circumstance, it forfeited any entitlement to deference. The Fourth Circuit affirmed that de novo review applied, found no error in the district court’s factual findings or legal conclusions, and upheld the award of benefits to the employee. View "Cogdell v. Reliance Standard Life Insurance Company" on Justia Law

The case involves a multi-employer pension fund seeking to collect withdrawal liability under the Multiemployer Pension Plan Amendments Act of 1980 from two corporate entities, which the fund alleged were successors to a defunct contributing employer. The companies denied any liability, contending they had never agreed to make contributions to the fund, were not under common control with the original employer, and were not otherwise subject to the fund’s claims. After the fund notified the companies of the alleged liability several years after the original employer ceased operations, the companies sought a declaratory judgment in federal court to clarify that they were not liable. The fund counterclaimed for withdrawal liability, as well as damages and interest.The United States District Court for the District of New Jersey found genuine disputes of material fact regarding whether the companies could be treated as employers under the applicable law, thus precluding summary judgment on that issue. Nevertheless, the District Court granted judgment in favor of the companies on a separate basis: it concluded that the fund’s eight-year delay in providing notice and demanding payment of withdrawal liability failed to meet the statutory requirement under 29 U.S.C. § 1399(b)(1) that such notice be given “as soon as practicable.” The court reasoned that this requirement is an independent statutory element—not an affirmative defense subject to waiver or arbitration—and that the fund’s failure to comply with it barred any recovery.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit held that timely notice and demand is a necessary element for a withdrawal liability claim to accrue under the MPPAA; if the fund fails to act “as soon as practicable,” its claim cannot proceed, regardless of whether the issue is raised in arbitration or by the parties. Arbitration was not required in this circumstance, and the District Court properly resolved the question. View "RTI Restoration Technologies Inc v. International Painters and Allied Trades Industry Pension Fund" on Justia Law

In this case, a school bus company’s employees voted in 2020 to change their union representation, shifting from a Teamsters local to an Amalgamated Transit Workers local. As a result, the company was required under federal law to withdraw from the multiemployer pension plan affiliated with the old union and begin contributing to a new plan aligned with the new union. This withdrawal triggered several obligations under ERISA, including the company’s duty to pay “withdrawal liability” to the old plan and the old plan’s obligation to transfer certain assets and liabilities to the new plan relating to the employees who switched unions.After the old pension fund assessed withdrawal liability of approximately $1.8 million, the company argued that, under 29 U.S.C. § 1415(c), this liability should be reduced by the difference between the liabilities and assets transferred to the new plan. The old plan disagreed, interpreting the statute differently and contending that no reduction should occur. The United States District Court for the Southern District of New York granted summary judgment to the company, holding that the statute required a $1.8 million reduction in withdrawal liability.On appeal, the United States Court of Appeals for the Second Circuit reviewed the District Court’s interpretation of the statute de novo. The Second Circuit found that the phrase “unfunded vested benefits” in Section 1415(c) is ambiguous, but, after examining the statute’s structure and purpose, concluded that the District Court’s interpretation was correct. The court held that “unfunded vested benefits allocable to the employer” under Section 1415(c) refers to the entire amount of liabilities transferred to the new plan, not reduced by transferred assets. As a result, the Second Circuit affirmed the District Court’s judgment, approving the $1.8 million withdrawal liability reduction and dismissing the company’s cross-appeal as moot. View "Mar-Can Transp. Co. v. Loc. 854 Pension Fund" on Justia Law

A former employee of a bank holding company, who participated in a company-sponsored retirement savings plan, brought suit alleging that the bank, the plan’s administrative committee, and a subsidiary breached their fiduciary duties under ERISA, resulting in financial loss to his plan distribution. After the employee’s separation and payout, the company amended the plan in early 2024 to add a retroactive arbitration clause that required all claims to proceed individually in arbitration, barred class or representative actions, and included a jury trial waiver and a provision that only individual relief could be awarded.The United States District Court for the Western District of Texas denied the defendants’ motion to compel arbitration, holding that the arbitration agreement was not valid under Texas law due to lack of consideration. The company appealed, arguing that the plan’s consent, not the individual participant’s, was sufficient to bind parties to arbitration for claims brought on behalf of the plan under 29 U.S.C. § 1132(a)(2), and that the arbitration clause was enforceable. The company also preemptively addressed potential objections under the effective vindication doctrine and claims that the arbitration provisions unlawfully limited statutory remedies.The United States Court of Appeals for the Fifth Circuit reversed the denial of arbitration as to the § 1132(a)(2) claim, holding that the plan’s consent through its unilateral amendment provision was sufficient to bind the participant to arbitration for plan-based claims, but affirmed the denial as to the participant’s individual claims because he had not consented. The court further held that the arbitration clause’s prohibition on representative actions and its limitation to individual relief violated the effective vindication doctrine, and voided the standard-of-review provision to the extent it applied to fiduciary-breach claims. The case was remanded for the district court to determine whether the offending arbitration provisions could be severed. View "Parrott v. International Bank" on Justia Law

Janet Duke, after retiring from Luxottica U.S. Holdings Corp., elected to receive pension benefits through a joint and survivor annuity (JSA), calculated using actuarial assumptions set by her employer’s defined benefit pension plan. Duke alleged that her plan used outdated assumptions—specifically, a 7% interest rate and life expectancy tables from 1971—to convert single life annuities (SLA) into JSA benefits, resulting in lower monthly payments for her and similarly situated retirees. She claimed this systematic practice violated ERISA’s requirements for actuarial equivalence and compliance, thereby potentially harming the plan’s participants and the plan itself.In the United States District Court for the Eastern District of New York, Duke filed a putative class action seeking relief under ERISA Sections 502(a)(2) and 502(a)(3), including plan reformation and monetary repayments to the plan. The district court initially found Duke lacked standing for Section 502(a)(2) claims but later reversed itself and held that she did have standing for both plan reformation and monetary payments. The court compelled individual arbitration of her Section 502(a)(3) claims under a dispute resolution agreement but held that the “effective vindication” doctrine prevented mandatory arbitration of her Section 502(a)(2) claims. Defendants’ motion for a mandatory stay of litigation pending arbitration was denied.The United States Court of Appeals for the Second Circuit reviewed the district court’s rulings. It held that Duke has Article III standing to pursue plan reformation under Section 502(a)(2) because her alleged injury—reduced benefits due to outdated assumptions—could be redressed by reformation of the plan. However, Duke lacks standing to seek monetary payments to the plan, as such relief would not redress any personal injury she suffered. The Second Circuit also held that the effective vindication doctrine precludes mandatory individual arbitration of her Section 502(a)(2) claim and affirmed the district court’s discretionary denial of a mandatory stay. The order was affirmed in part and reversed in part. View "Duke v. Luxottica U.S. Holdings Corp." on Justia Law

Carl Kleinfeldt was a longtime employee who participated in his employer’s retirement plan. He originally designated his wife, Dená Langdon, as the primary beneficiary and his sisters as contingent beneficiaries. After divorcing Langdon in September 2022, Kleinfeldt sent a fax to his employer’s benefits center requesting that Langdon be removed as beneficiary from his retirement accounts. Although the employer updated Langdon’s status from “spouse” to “ex-spouse,” she remained listed as the primary beneficiary at the time of Kleinfeldt’s death in January 2023.Following Kleinfeldt’s death, the employer planned to distribute the retirement account funds to Langdon. Both Langdon and Kleinfeldt’s estate submitted competing claims to the employer, which denied the estate's claim but allowed an appeal. When conflicting claims persisted, the employer filed an interpleader action in the United States District Court for the Western District of Wisconsin and deposited the funds with the court. During litigation, the district court determined that Kleinfeldt’s sister, Terry Scholz, also had a potential claim as a surviving contingent beneficiary and joined her estate as a necessary party. After cross-motions for summary judgment, the district court denied both and instead granted summary judgment sua sponte to Scholz’s estate, finding that Kleinfeldt had substantially complied with the plan’s requirements to remove Langdon as beneficiary.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment de novo. The appellate court held that Kleinfeldt did not meet the requirements of substantial compliance because he failed to follow the plan’s specified procedures for changing a beneficiary, which required contacting the benefits center or updating beneficiaries online—not simply sending a fax. The Seventh Circuit reversed the district court’s judgment and remanded with instructions to enter judgment in favor of Langdon as the primary beneficiary. View "Packaging Corporation of America Thrift Plan for Hourly Employees v. Langdon" on Justia Law

A multiemployer pension plan regulated under ERISA and the Multiemployer Pension Plan Amendments Act (MPPAA) sought to recover withdrawal liability from Florida Glass of Tampa Bay and related entities after Florida Glass ceased performing covered work and entered bankruptcy. In 2016, the pension plan filed a contingent proof of claim in Florida Glass’s bankruptcy proceedings, but did not clearly determine or assert withdrawal liability at that time. Several years later, after confirming withdrawal had occurred, the plan issued a formal notice and demand for payment. The defendants did not timely seek arbitration under the statutory process, and, when sued to collect the withdrawal liability, argued that the plan’s earlier bankruptcy filing constituted both a statutory notice and demand and an acceleration of liability, thus triggering the statute of limitations before the suit was filed.The United States District Court for the District of Maryland rejected the defendants’ statute of limitations defense. The court held that the 2016 contingent proof of claim was neither a notice and demand nor an acceleration under the MPPAA, so the limitations period did not begin until the 2022 notice and demand letter. Alternatively, the court reasoned that even if the 2016 filing qualified as a notice and demand, the defendants had waived any related defenses by failing to timely arbitrate. The court granted summary judgment for the pension plan and awarded damages, interest, attorney’s fees, and costs, minus the bankruptcy distribution already received.The United States Court of Appeals for the Fourth Circuit affirmed. The court held that a contingent proof of claim does not constitute a notice and demand, nor an acceleration, unless it clearly satisfies the statutory requirements. Since the 2016 filing was ambiguous and labeled contingent, it did not trigger the statute of limitations, rendering the suit timely. The court affirmed the judgment and associated relief for the pension plan. View "International Painters and Allied Trades Industry v. Florida Glass of Tampa Bay, Inc." on Justia Law

A parent enrolled his teenage son, who had a history of serious behavioral and mental health issues, in a residential treatment center after other interventions failed. The family’s health insurer initially approved and paid for the first 21 days of residential treatment, then denied further coverage, asserting that the treatment was no longer medically necessary. The parent appealed this decision through the insurer’s internal process, submitting medical records and opinions from the child’s treating clinicians that supported the need for continued residential care. The insurer upheld its denial after cursory reviews that did not address the treating clinicians’ recommendations or key evidence of the child’s ongoing difficulties.The parent filed suit in the United States District Court for the Western District of Kentucky, alleging that the insurer’s denial was arbitrary and capricious under the Employee Retirement Income Security Act (ERISA) and violated the Mental Health Parity and Addiction Equity Act. The district court granted summary judgment to the insurer on both claims, finding that the decision to deny coverage was not arbitrary and capricious and that there was no evidence of a parity violation.On appeal, the United States Court of Appeals for the Sixth Circuit found that the insurer’s coverage decision was procedurally arbitrary and capricious, as it failed to consider the treating clinicians’ opinions, selectively reviewed the medical record, and did not adequately explain its change from initially approving coverage to denying it. The appellate court vacated the district court’s judgment on the ERISA claim and remanded with instructions to send the matter back to the insurer for a full and fair review. However, it affirmed the district court’s judgment on the Parity Act claim, holding that the parent failed to produce evidence showing that the insurer’s limitations on mental health treatment were more restrictive than those applied to medical or surgical benefits. View "T. E. v. Anthem Blue Cross Blue Shield" on Justia Law

JB Viva Vegas, L.P. challenged the assessment of withdrawal liability imposed by the Nevada Resort Association-International Alliance of Theatrical Stage Employees and Moving Picture Machine Operators of the US and Canada Local 720 Pension Trust under the Multiemployer Pension Plan Amendments Act (MPPAA). JB had contributed to the Trust’s pension plan for stagehands working on a theatrical production, which later closed. The Trust asserted withdrawal liability, arguing that its plan no longer qualified for the entertainment industry exception due to a shift in employee work from entertainment to convention-related activities.After JB’s request for review went unanswered, it initiated arbitration. The arbitrator initially ruled in JB’s favor, finding the plan qualified for the entertainment exception and ordering rescission of the withdrawal liability. The Trust then sought to vacate the arbitration award in the United States District Court for the District of Nevada. The district court vacated the award, reasoning that the relevant year for determining the plan’s status was the year JB withdrew, not when it joined, and remanded to the arbitrator. On remand, the arbitrator granted summary judgment to the Trust, concluding that the MPPAA was ambiguous as to how much entertainment work was required and that the plan did not “primarily” cover entertainment employees because less than half earned most of their wages from entertainment work. The district court affirmed the arbitrator’s decision, granting summary judgment to the Trust.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s summary judgment de novo. The court held that the MPPAA’s entertainment industry exception does not require a minimum amount of entertainment work for an individual to qualify as an “employee in the entertainment industry.” Therefore, the Trust’s plan primarily covers such employees if a majority perform any entertainment work. The Ninth Circuit reversed the district court’s decision and remanded the case. View "NEVADA RESORT ASSOCIATION-INTERNATIONAL ALLIANCE OF THEATRICAL STAGE EMPLOYEES AND MOVING PICTURE MACHINE OPERATORS OF THE US AND CANADA LOCAL 720 PENSION TRUST V. JB VIVA VEGAS, LP" on Justia Law

A construction company in southern Nevada ceased contributing to a multiemployer pension plan after it stopped operating in the state. The pension plan’s trustees assessed the company for withdrawal liability, asserting the company owed over $2.8 million under the Multiemployer Pension Plan Amendments Act (MPPAA). The company challenged the assessment, arguing it was exempt from liability because its asbestos abatement work qualified for the “building and construction industry” exception in the MPPAA. The company pointed out that asbestos abatement involves removing or remediating hazardous materials from buildings, including demolition and substantial alterations to structures.An arbitrator initially ruled in favor of the pension plan’s trustees, interpreting the “building and construction industry” narrowly to include only work that literally builds new structures, and finding that asbestos abatement did not meet this definition. The company then brought suit in the United States District Court for the District of Nevada to vacate or modify the arbitration award. The district court rejected the arbitrator’s and trustees’ narrow construction, instead adopting a broader understanding of the industry that includes maintenance, repair, alteration, and demolition. The district court granted summary judgment to the company, holding that its asbestos abatement work qualified for the statutory exception, and ordered the return of payments made toward the assessed liability.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The Ninth Circuit held that the phrase “building and construction industry” in the MPPAA incorporates the definition established by the National Labor Relations Board under the Taft-Hartley Act, which includes erection, maintenance, repair, and alteration of buildings and structures. Applying this definition, the court ruled that asbestos abatement is covered by the exception, exempting the company from withdrawal liability. View "WALKER SPECIALTY CONSTR., INC. V. BD. OF TR. OF THE CONSTR. INDUS. AND LABORERS JOINT PENSION TRUST" on Justia Law