Justia ERISA Opinion Summaries

After Employee ended his employment with Employer he applied for and received state unemployment benefits from the Department of Employment and Economic Development (DEED) and supplemental unemployment benefits (SUB) through a plan offered by Employer. DEED determined that the SUB plan payments counted as “wages” under Minn. Stat. 268.035(29)(A) and determined that Employee had been overpaid state unemployment benefits. An unemployment law judge affirmed. The court of appeals reversed, concluding that Employee was entitled to keep the state unemployment benefits. The Supreme Court affirmed, holding the SUB plan payments Employee received were not “wages” for purposes of his eligibility for state unemployment benefits, and therefore, Employee was not overpaid state unemployment benefits. View "Engfer v. Gen. Dynamics Advanced Info. Sys., Inc." on Justia Law

Michels is a member of the Pipe Line Contractors Association (PLCA), a trade association that negotiates collective bargaining agreements (CBAs) on behalf of its employer members with unions. In 2006, the PLCA and the Union entered into a CBA in “effect until January 31, 2011, and thereafter from year to year unless terminated at the option of either party after sixty (60) days’ notice.” The CBA required contributions to the Central States multiemployer pension plan, 29 U.S.C. 1000(2), (3), (37). In August 2010, the PLCA informed the Union that it intended to terminate the 2006 CBA on January 31, 2011, and begin negotiations for a new agreement; the parties signed eight extensions, the last ending November 15, 2011. Michels contributed to the pension plan throughout those extensions. The parties agreed that the employers would cease making contributions to the plan as of November 15, 2011; that they would make comparable payments to an escrow fund until a “mutually acceptable” fund was designated; and that they would otherwise extend the terms of the 2006 CBA until December 31, 2011. The fund claimed that the obligation to make contributions had not ended. The Seventh Circuit reversed the district court holding that this was not sufficient to end the duty to contribute. View "Michels Corp. v. Cent. States, SE & SW Areas Pension Fund" on Justia Law

The Iron Workers negotiated a contract that required JD Steel to make contributions, on behalf of its employees, to the pension funds for local unions in which the employees performed work, amounting $10.00 for every hour that a JD employee worked in the local union's territory. Later, the Iron Workers negotiated a similar contract with Davis Rebar, except that, rather than require contributions to the local unions’ pension funds, the contract required Davis to make identical contributions to the local unions’ defined-contribution plans, such as a 401(k) plan. In 2013, JD worked on a parking garage at Cleveland’s Fairview Hospital while Davis worked on a garage at University Hospital. Both jobs were within the territory of the Local 17 Iron Workers Union. Davis apparently used equipment bearing JD’s name and logo. The companies shared a foreman and supervisors. The pension plan sued under 29 U.S.C. 1132(a)(3), alleging that JD and Davis are actually the same company, so that Davis is bound by JD’s contract and must make additional payments. Each company has made all payments required by its individual contract. The Sixth Circuit affirmed dismissal. Reasoning that the same association of unions negotiated and signed both agreements, the court declined to set aside the association’s judgment regarding its members’ best interests. View "Bd. Trs. Local 17 Iron Workers Pension Fund v. Harris Davis Rebar LLC" on Justia Law

Joseph Martinez was a participant in the Plumbers and Pipefitters National Pension Plan, (governed by the Employee Retirement Income Security Act (ERISA)). Following some health problems, Martinez retired from plumbing in 2004 at age 56 and took advantage of the Plan’s early retirement pension. After a few years in retirement, he felt well enough to resume working, and his pension was suspended during that time according to rules that prohibit retirement benefits during disqualifying employment. When he retired again in 2009, he asked the National Pension Fund to allow him to convert the pension benefits he previously elected from an early retirement pension to a disability pension (a change that would have entitled him to higher monthly payments). The Fund denied the conversion and the district court upheld the denial. After review, the Tenth Circuit agreed with the district court that the Plan language was unambiguous and allowed Plan participants to apply for and receive only one type of pension benefit for life absent several clearly delineated exceptions, none of which applied to Martinez. Accordingly, the Court affirmed the Fund’s denial of Martinez’s claim for disability benefits. View "Martinez v. Plumbers & Pipefitters" on Justia Law

In Sprint Commc’ns, Inc. v. Jacobs, the Supreme Court revisited the doctrine of abstention enunciated in Younger v. Harris. That doctrine requires federal courts, in the absence of extraordinary circumstances, to refrain from interfering with certain state proceedings. In this case, David Knight, an employee of Sirva Relocation, LLC, filed a charge of discrimination with the Massachusetts Commission Against Discrimination (MCAD) alleging that Sirva and Aetna Life Insurance Company (together, Appellants) had discriminated against him on the basis of disability in violation of Mass. Gen. Laws ch. 151B and the Americans with Disabilities Act (ADA). Appellants filed a federal complaint against the Commonwealth of Massachusetts, the MCAD, its commissioners, and Knight, asking the court to enjoin the MCAD proceeding on the basis that ERISA preempted the chapter 151B claim. The MCAD and Knight moved to dismiss the complaint, entreating the district court to abstain. While the case was pending, the Supreme Court decided Sprint. The district court dismissed the federal court action, concluding that Younger abstention was appropriate in this case. The First Circuit affirmed the district court’s decision to abstain and further clarified its own case law concerning the exception to the Younger doctrine for facially conclusive claims of preemption. View "Sirva Relocation, LLC v. Golar Richie" on Justia Law

Petitioner, the former State director of United Public Workers, AFSCME Local 646, FL-CIO (UPW) and a former administrator of UPW’s Mutual Aid Fund trust (MAF), was held liable by a federal district court for negligently making loans under ERISA and thus breaching his fiduciary duties to the MAF. The court entered judgment against Petitioner in the amount of $850,000. Petitioner filed a complaint in the circuit court requesting that UPW indemnify him for the $850,000 on the grounds that his liability to the MAF arose from actions he took solely in his capacity as agent for UPW and/or that UPW ratified his actions. The circuit court granted summary judgment for UPW. The Intermediate Court of Appeals (ICA) affirmed, concluding that because Petitioner was responsible for his own conduct, he was not entitled to be indemnified for his negligent acts as a matter of law. Petitioner requested certiorari, claiming that the ICA erred in concluding that his negligence claim defeated his indemnification claim as a matter of law. The Supreme Court denied certiorari without reaching this issue, holding that ERISA preemption, not Petitioner’s negligence, defeated Petitioner’s state indemnity claims against UPW as a matter of law. View "Rodrigues v. United Public Workers, AFSCME Local 646" on Justia Law

Nine multi-employer pension and welfare fringe benefit trust funds sued G&W Construction and its president, under the Labor Management Relations Act, 29 U.S.C. 185(a), and the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1145, to recover delinquent fringe-benefit payments under a contract between G&W and the Union. The defendants raised affirmative defenses of laches, estoppel, and waiver, alleging that the Union led G&W to believe that fringe benefit payments were due only for union members and that G&W relied upon the acts and omissions of the Union and the funds by bidding and accepting work on the reasonable understanding that Union wages and benefits did not apply to non-members. The Funds moved to strike the affirmative defenses, arguing that ERISA bars equitable defenses. The district court denied the motion to strike. The Sixth Circuit reversed in part. The district court should have granted the motion to strike the defenses of laches and equitable estoppel; the court declined to consider the district court’s ruling on the waiver defense. View "Operating Eng'rs Local 324 v. G & W Constr. Co." on Justia Law

Appellant was eligible for disability benefits through an employee welfare benefit plan underwritten by Aetna Life Insurance Company. Appellant successfully applied for long-term disability (LTD) benefits under his plan in 2009. Later that year, Appellant’s LTD benefits were terminated. Appellant brought this suit against Aetna under the Employee Retirement Income Security Act of 1974 alleging wrongful termination of benefits. The federal district court granted summary judgment for Aetna on the benefits-termination claim but applied a $5,000 penalty against Aetna for its failure to produce all relevant plan documents within the statutorily prescribed time. The First Circuit (1) vacated summary judgment with respect to the termination of disability benefits and remanded the issue for further consideration by the claims administrator, holding that Aetna’s decision to terminate Appellant’s LTD benefits was not a reasoned determination; and (2) affirmed the district court’s imposition of a $5,000 penalty for the belated production of a plan document, holding that the amount of the penalty imposed was within the district court’s discretion. View "McDonough v. Aetna Life Ins. Co." on Justia Law

Home health care plaintiffs sought to prevent the Commissioner of the New York State Department of Health, from enforcing the Wage Parity Law, which sets the minimum amount of total compensation that employers must pay home care aides in order to receive Medicaid reimbursements for reimbursable care provided in New York City and Westchester, Suffolk, and Nassau Counties, N.Y. Pub. Health Law 3614‐c. Plaintiffs claim the Law was either preempted by the National Labor Relations 8 Act, 29 U.S.C. 151, or the Employee Retirement Income Security Act, 29 U.S.C. 1001, or was unconstitutional under the Due Process and Equal Protection Clauses. The Second Circuit affirmed the district court conclusion that the state law, except for one severable provision subdivision that singles out Taft‐Hartley plans for special treatment, is neither preempted nor unconstitutional. View "Concerned Home Care Providers, Inc. v. Cuomo" on Justia Law

Plaintiffs-appellants represent a class of retirees formerly employed by Sprint-Nextel Corporation, Embarq Corporation (or a predecessor and/or subsidiary company of either Embarq or Sprint). Plaintiffs sued after Defendants altered or eliminated health and life insurance benefits for retirees. Plaintiffs asserted Defendants: (1) violated the Employee Retirement Income Security Act of 1974 (ERISA) by breaching their contractual obligation to provide vested health and life insurance benefits; (2) breached their fiduciary duty by, inter alia, misrepresenting the terms of multiple welfare benefit plans; and (3) violated the Age Discrimination in Employment Act (ADEA) and applicable state laws by reducing or eliminating the same benefits. Defendants moved for summary judgment on the breach of fiduciary duty claims, the ADEA claims, the state-law age discrimination claims, and some of the contractual vesting claims. The district court granted Defendants’ motions in part and Plaintiffs obtained a Rule 54(b) certification. The Tenth Circuit concluded Defendants did not contractually agree to provide Plaintiffs with lifetime health or life insurance benefits and thus affirmed in part the grant of summary judgment as to the contractual vesting claims. To the extent the district court granted summary judgment against class members whose contractual vesting claims arise, in whole or in part, from summary plan descriptions (other than those identified in Defendants’ motion), the Court reversed the grant of summary judgment against those class members. The Court reversed the district court’s dismissal of Plaintiffs’ breach of fiduciary duty claims brought pursuant to 29 U.S.C. 1132(a)(3) and reversed the dismissal of Plaintiffs’ remaining breach of fiduciary duty claims to the extent those claims were premised on a fraud theory. Finally, because Defendants’ decision to reduce or terminate the group life insurance benefit was based on a reasonable factor other than age, their actions did not violate the ADEA, and the Tenth Circuit affirmed the grant of summary judgment in favor of Defendants on those claims. View "Fulghum v. Embarq Corporation" on Justia Law