Justia ERISA Opinion SummariesArticles Posted in U.S. 11th Circuit Court of Appeals
Lanfear, et al. v. Home Depot, Inc., et al.
Plaintiffs claimed that the fiduciaries of their retirement plan violated the Employment Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., in ways that damaged their efforts to stockpile savings for their winter years. The court held that because plaintiffs have not pleaded facts establishing that defendants abused their discretion by following the Plan's directions, they have not stated a valid claim for breach of the duty of prudence. The court also held that plaintiffs have failed to state a viable breach of loyalty claim. Accordingly, the court affirmed the district court's dismissal of plaintiffs' third and last amended complaint. View "Lanfear, et al. v. Home Depot, Inc., et al." on Justia Law
Cinotto v. Delta Air Lines, Inc., et al.
This appeal involved an anti-cutback rule in section 204(g) of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1054(g). Specifically, section 204(g)'s anti-cutback rule forbid, with a few exceptions, a pension plan amendment that decreased a participant's "accrued benefit." At issue was whether this pension plan amendment violated the anti-cutback rule when it changed the calculation of that Social Security offset for participants who had not yet reached age 52, the plan's earliest retirement age, at the time of the amendment. The court held that it did not where Amendment Eight did not come within the scope of ERISA's anti-cutback rule and the anti-cutback rule protected only an accrued benefit from being reduced by plan amendment. The anti-cutback rule did not protect a mere expectation based on anticipated years of future employment. Accordingly, the court affirmed the judgment of the district court. View "Cinotto v. Delta Air Lines, Inc., et al." on Justia Law
Ehlen Floor Covering, Inc., et al. v. Innovative Pension Strategies, Inc.
IPS appealed the district court's denial of its motion to compel arbitration and stay plaintiffs' claims against it. Plaintiffs cross-appeal, disputing the preemption of their claims under the Employment Income Security Act (ERISA), 29 U.S.C. 1001 et seq., and alleging a lack of federal jurisdiction. The court found that jurisdiction was proper and affirmed the district court's denial of IPS's motion to compel arbitration. View "Ehlen Floor Covering, Inc., et al. v. Innovative Pension Strategies, Inc." on Justia Law
Blankenship v. Metropolitan Life Ins. Co.
Plaintiff challenged the denial of his claims for long-term disability benefits by defendant, who served as both the administrator of claims and the payor of benefits in the long-term disability plan in which defendant participated. At issue was whether there was a conflict of interest where defendant was both administrator and payor of benefits of the plan governed by ERISA, 29 U.S.C. 1001-1461. The court found that defendant considered the medical information submitted by plaintiff's doctors and relied upon the advice of several independent medical professionals to conclude that plaintiff failed to make a sufficient showing of disability under the plan and, even where plaintiff's own doctors offered different medical opinions than defendant's independent doctors, the plan administrator could give different weight to those opinions without acting arbitrarily or capriciously. Therefore, the court held that a reasonable basis supported defendant's benefits decisions and that the conflict of interest did not render the decisions arbitrary or capricious. View "Blankenship v. Metropolitan Life Ins. Co." on Justia Law
Ward v. The Retirement Board of Bert Bell, et al.
Kurt R. Ward, Attorney at Law, LLC, appealed the district court's order denying its motion for judgment on the pleadings and granting the Plan Parties' (the Bert Bell/Pete Rozelle NFL Player Retirement Plan, the Retirement Board of the Plan, and the Bank of New York Mellon Corporation) cross-motion for judgment on the pleadings. Both parties' motions sought a declaration about whether the Plan Parties had to pay the disability benefits of two of the Ward Firm's retired NFL player clients into the firm's client trust account pursuant to state court jurisdiction for unpaid attorney's fees despite a provision in the Plan prohibiting any "benefit under the Plan" from being assigned or reached by creditors through legal process. The court held that its prior panel precedent held that bargained-for provisions barring assignments in ERISA welfare benefits were valid and enforceable and that the Ward Firm had not directed the court's attention to any such intervening en banc or Supreme Court decision. Accordingly, the court affirmed the judgment and held that the district court did not err in declaring that the spendthrift provision in the Plan prevented the Plan Parties from depositing the disability benefits owned by two retired NFL players into the Ward Firm's trust account. View "Ward v. The Retirement Board of Bert Bell, et al." on Justia Law