Justia ERISA Opinion Summaries

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

When an employer participating in a multi-employer pension plan withdraws from the plan with unpaid liabilities, federal law can pierce corporate veils and impose liability on owners and related businesses. The Fund is a multi-employer pension plan under the Employee Retirement Income Security Act/Multiemployer Pension Plan Amendments Act, 29 U.S.C. 1381-1461. Messina Trucking was subject to a collective bargaining agreement that required it to contribute to the Fund for retirement benefits. Messina Trucking permanently ceased to have an obligation to contribute to the Fund, triggering a “complete withdrawal” and incurring nearly $3.1 million in potential withdrawal liability. The Fund sought a declaratory judgment that defendants were jointly and severally liable for the withdrawal liability as “trades or businesses” under “common control” with Messina Trucking. The district court held that Mr. and Mrs. Messina, who owned and leased several residential properties as well as the property from which Messina Trucking operated, were not engaged in a “trade or business” and could not be held liable for the withdrawal liability, but that Messina Products, as a formal business organization could be held liable for Messina. The Seventh Circuit ruled in favor of the Fund, holding that both can be held liable. View "Cent. States Se & Sw Areas Pension Fund v. Messina" on Justia Law

Hostess provided an "employee welfare benefit plan" under the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1002(1). In this appeal, appellant challenged the order of the district court affirming the grant of summary judgment by the bankruptcy court in favor of Hostess on his claim for civil penalties for Hostess's failure to give notice of certain health insurance coverage rights required under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA), 29 U.S.C. 1166(a), and the denial of attorney's fees. Although it was undisputed that Hostess failed to provide two notices required by COBRA, the court rejected appellant's arguments and held that the bankruptcy court did not err in granting summary judgment to Hostess on his claim for civil penalties. The court agreed with the bankruptcy court that it could not "fairly call the outcome of the litigation some success on the merits" as required to award attorney's fees and costs to appellant. View "Deckard v. Interstate Bakeries Corp., et al" 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

Plaintiff, a former software developer for Lockheed Martin Corporation, brought this action for judicial review after Connecticut General terminated his disability benefits in 2007. The court held that the district court properly applied an abuse of discretion standard; on the record, it was not an abuse of discretion to terminate plaintiff's benefits; and the district court did not err in denying plaintiff an opportunity to depose the expert at issue. Accordingly, the court affirmed the judgment. View "Siegel v. Connecticut General Life Ins., et al" on Justia Law

In 1992 Navistar attempted to reduce its costs for retired employee health and life insurance benefits. Navistar’s retirement benefit plan is a registered employee health benefit plan under the Employee Retirement Income Security Act, 29 U.S.C. § 1001 and Navistar is both plan administrator and fiduciary. In 1993, the district court entered judgment in a class action challenging the change, adopting an agreement between the parties and retaining jurisdiction. The Agreement established the Retiree Health Benefit and Life Insurance Plan. The Plan established the Health Benefit Program Summary Plan Description, which contains a description of the health benefits and is furnished to all beneficiaries. The Agreement divides health benefits into two plans: Plan 2 for those eligible for Medicare and Plan 1 for those who are not eligible. A prescription drug benefit was provided under the Agreement, identical for both Plan 1 and Plan 2. When Navistar moved to substitute Medicare Part D into the Plan, class members claimed violation of the Agreement. The district court ordered Navistar to reinstate, retroactively, the prescription drug benefit that was in effect before Navistar made the unilateral substitution. The Sixth Circuit affirmed,View "Shy v. Navistar Int'l Corp." on Justia Law

This dispute related to Employee Retirement Security Act (ERISA), 29 U.S.C. 1001 et seq., contributions made pursuant to a collective bargaining agreement. The district court ordered return of certain allegedly mistaken employer contributions even though the plan administrator determined that the contributions were not made by mistake. Because the court found that the administrator's decision was not an abuse of discretion, the court reversed and remanded for further proceedings. View "U.S. Foodservice, Inc. v. Truck Drivers & Helpers Union" on Justia Law

Raybourne was a quality engineer for 23 years. The employer provided a long-term disability plan that paid benefits for up to 24 months if disability prevented him from performing the duties of his regular job. After 24 months, the plan paid benefits only if he was unable to perform all material duties of any occupation for which he was reasonably qualified. Raybourne suffered degenerative joint disease in his foot, with severe pain. In 2003, he stopped working and underwent the first of the four surgeries. From December 2003 through February 2006, Cigna paid benefits, then determined that he was not disabled under the more stringent standard. Raybourne exhausted administrative remedies, then sued under 29 U.S.C. 1132(a)(1)(B). The district court ruled in favor of Cigna. On remand the court rejected Cigna’s “unconvincing” explanation for how the company determined that Raybourne was not disabled. The court found that Cigna relied on the report of a non-treating physician and on the Social Security Administration’s initial rejections of Raybourne’s claim, failing to consider the SSA’s final determination of disability. The Seventh Circuit affirmed, finding that denial of benefits was based on a conflict of interest rather than on the facts and the terms of the policy. View "Raybourne v. CIGNA Life Ins. Co. of NY" on Justia Law

After they were fired from their jobs, Appellants filed suit in federal district court against their former employer (Employer) and against the severance plan (Plan) established by Employer pursuant to ERISA. The complaint asserted federal claims under ERISA, ADEA, ADA, and other federal laws, and also asserted a breach of contract claim, an employment discrimination claim, and an unjustified dismissal claim under Puerto Rico law. The district court granted Appellees' motion for summary judgment. Appellants challenged that ruling as well as a number of the district court's other orders. The First Circuit Court of Appeals affirmed, holding that there was no error in the management of this case or the grant of Appellees' motion for summary judgment. View "Cruz v. Bristol-Myers Squibb Co., PR, Inc." on Justia Law