Justia ERISA Opinion Summaries

Plaintiffs appealed from the judgment of the district court dismissing as time-barred their putative class action complaint against their former employer and the employer's pension plan for benefits alleged to be due under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs asserted that the district court erred when it looked past the six-year New York limitations period for contract actions; applied part of the New York regime known as the "borrowing statute," which directed it to Pennsylvania law; and ruled that Pennsylvania's four-year limitations period barred plaintiffs' claims. The court held that in an action for benefits under 29 U.S.C. 1132, the court applied the forums state's statute of limitations, including its borrowing statute. Therefore, the district court was correct in applying New York's borrowing statute and plaintiffs' claims were untimely under Pennsylvania law. View "Muto, et al. v. CBS Corp." on Justia Law

The former trustees of the Plasterers' Local Union No. 96 Pension Plan appealed from the judgment of the district court in favor of the current trustees of the Plan. The district court's judgment was based on its finding that the former trustees breached their fiduciary duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., regarding the investment Plan assets set forth under 29 U.S.C. 1104(a)(1)(B) and (C). On appeal, the former trustees challenged the district court's determination as to liability, its method of calculating damages, and the award of attorney fees. The court concluded that the district court erred as to each of these issues and therefore vacated the judgment and remanded the case for further proceedings. View "Plasterer's Local Union No. 96 v. Pepper" on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)-(3), seeking to recover funds that were erroneously removed from his pension fund account and credited to that of his former wife. The district court entered judgment against defendant in the amount of $1,571,723.73, which included the principal amount, accumulated earnings and pre-judgment interest. On appeal, defendant argued that enforcement of the judgment was prohibited by the terms of the pension agreement, ERISA's anti-alienation provision, and other provisions of federal and state law. Defendant also argued that the district court's award of accumulated earnings was inconsistent with the court's decision in Dobson v. Hartford Financial Services Group, Inc. Applying the appropriate standards of review, the court found defendant's arguments were without merit and affirmed the judgment of the district court. View "Milgrim v. Orthopedic Assoc." on Justia Law

Plaintiff Dennis Carter began working as a directional driller at Pathfinder Energy Services, Inc., in December 2004. Two years later, declining health had caused a reduction in Plaintiff's workload. Pathfinder fired Plaintiff for "gross misconduct" based primarily on an altercation that he had had with a coworker and his language and attitude during a conversation with his supervisor. Plaintiff sued Pathfinder in federal district court, alleging that Pathfinder had violated his rights under the Americans with Disabilities Act (ADA) and the Employee Retirement Income Security Act (ERISA). He also alleged that Pathfinder had breached his implied-in-fact employment contract. The district court granted summary judgment in favor of Pathfinder on all three claims. Upon careful review, the Tenth Circuit reversed the district court’s grant of summary judgment on Plaintiff's ADA claim, but affirmed the grant of summary judgment on the remaining claims. Specifically, the Tenth Court held that "[a] reasonable jury could conclude that [Plaintiff] has made out a prima facie case of discrimination and has established that Pathfinder’s asserted justification for his firing was pretextual. At this stage of the case, that is enough." The Court remanded the case for further proceedings on the ADA claim. View "Carter v. Pathfinder Energy" on Justia Law

This appeal and cross-appeal concerned the pension benefits owed to plaintiff, a retired carpenter, and members of a class he purported to represent. Plaintiff asserted that the pension fund was guilty of seven violations of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., and sought declaratory and injunctive relief. The court agreed with the district court that defendants' interpretations of certain plan language was arbitrary and capricious and therefore affirmed the district court's award of summary judgment to plaintiff on his individual claims for miscalculation of pension benefits. The court concluded, however, contrary to the district court, that the six-year statute of limitations applicable to plaintiff's and each other putative class member's ERISA claims began to run when each pensioner knew or should have known that defendants had miscalculated the amount of his pension benefits, and that he was being underpaid as a result. Therefore, the court vacated the district court's judgments certifying the plaintiff class, granting summary judgment to the class, and granting prejudgment interest to the class members. The court remanded for further factfinding with regard to when each putative class member became, or should have become, aware of his alleged injury so as to begin the running of the statute of limitations as applied to him. View "Novella v. Westchester County, et al." on Justia Law

Plaintiff Steven Lucas filed suit against Liberty Life Assurance Company of Boston (Liberty Life), asserting that the company violated the Employee Retirement Income Security Act of 1974 (ERISA) when it denied his claim for long term disability benefits. Finding that the denial of benefits was not arbitrary and capricious, the district court entered judgment in favor of Liberty Life. Plaintiff appealed the district court's decision. Plaintiff was an employee of the Coca-Cola Company. Liberty Life both administered and insured Coca-Cola's long-term disability benefits plan. Under the plan, it has discretionary authority to determine eligibility for benefits. Plaintiff suffered a work-related injury requiring spinal surgery and, after a short period back on the job, stopped working. He filed a claim for long-term disability benefits in August 2005. In September 2007, Liberty Life terminated Plaintiff's benefits after determining that he was not eligible for continued benefits under the "any occupation" provision: while he might not be capable of performing his own occupation, he was capable of performing some occupation comparable to his former position. Plaintiff filed an administrative appeal with Liberty Life, but the company upheld the denial of benefits. Upon review, the Tenth Circuit concluded that Liberty Life's decision was supported by substantial evidence, and that Plaintiff failed to show that it was arbitrary and capricious. Accordingly, the Court affirmed the district court's decision. View "Lucas v. Liberty Life Assurance Company" on Justia Law

Appellant was terminated for cause from his employment with Northwest Airlines shortly after he was arrested for possession of marijuana. At the same time, appellant had pending with Northwest a request for disability retirement benefits. Northwest later granted appellant's request, but he was ineligible for certain retirement benefits as a result of the termination. Appellant sued Northwest, claiming that the termination violated section 510 of the Employment Retirement Income Security Act (ERISA), 29 U.S.C. 1140. The district court denied Northwest's motion to dismiss for lack of subject-matter jurisdiction, but granted its motion for summary judgment. The court held that the district court properly exercised jurisdiction over the case where appellant's claim did not require an interpretation of a collectively bargained agreement. The court also held that appellant failed to show a causal connection between his termination and his application for disability retirement benefits. The court rejected appellant's remaining arguments. Accordingly, the court affirmed the judgment of the district court. View "Sturge v. Northwest Airlines, Inc." on Justia Law

Plaintiff sued his former employer under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001, et seq., to recover profit sharing and retirement benefits that were allegedly withheld from him. The district court granted summary judgment for plaintiff on his claims that the employer breached its fiduciary duty of loyalty and violated ERISA's disclosure requirements. The district court also awarded plaintiff statutory penalties and attorney's fees. The court affirmed the district court's award of damages for breach of fiduciary duty and attorney's fees. The court held, however, that the summary allocation report contained no information about how a participant could elect to receive a rollover distribution, nor did it inform the participant of her rights under the profit-sharing plan. Therefore, the court remanded to the district court for additional findings on whether the employer failed to furnish plaintiff with the requisite documents under ERISA 104(b)(1), and if so, whether that omission served as a basis for statutory penalties. View "Kujanek v. Houston Poly Bag I, Ltd." on Justia Law

In 2007 employee retired when the steel plant, at which he had worked for 42 years, shut down. Under a plan negotiated by the union, his pension payment, without any offset, was $688.13 a month. Employee was told that payment of his pension would be deferred for more than 10 years because the plan required that employee pay back workers' compensation settlements that he had received after sustaining on-the-job injuries in 2005 and 2006. The plan refers to offset for payments for "disability in the nature of a permanent disability for which the Company is liable." The district court entered judgment for the employee. The Seventh Circuit reversed. The committee's decision was within its discretion; the plan's specific mention of workers' compensation supports its characterization. View "Frye v. Thompson Steel Co., Inc." on Justia Law

When an employee left the company in 1997, took a $47,850 lump sum distribution of his pension. He later believed that the payment should have included the present value of future cost of living adjustments that would have been included had he received his pension as an annuity. In 2002, he filed a class action suit. The district court granted summary judgment on liability in favor of the class and the Seventh Circuit affirmed, holding that a COLA is an accrued benefit, as defined in ERISA, 29 U.S.C. 1002(23)(A). Before the district court ruled, the parties reached a settlement that each early retiree would receive roughly 3.5% of her original lump sum, unless the COLA on a normal-retirement-age-based annuity outweighed her early-retirement subsidy, a rare situation. The district court approved the proposed settlement and awarded attorney's fees. Objectors were not allowed to opt out. The Seventh Circuit affirmed, upholding determinations that the settlement was reasonable; that class counsel had adequately represented the early retirees and that further subclasses were unnecessary; that opt-out should be denied; and concerning attorney fees. View "Adamski v. Rohm & Haas Pension Plan" on Justia Law