Justia ERISA Opinion SummariesArticles Posted in U.S. 1st Circuit Court of Appeals
Gross v. Sun Life Assurance Co. of Canada
Appellant was placed on disability leave from work. Appellant was covered under a long term disability (LTD) policy that her employer obtained from Medical Group Insurance Services (MGIS). The policy was written by Sun Life Assurance Company (Sun Life). After leaving her job, Appellant filed a claim with MGIS seeing long term disability benefits. Sun Life denied Appellant's request for benefits. Appellant filed an action against Sun Life, asserting various state law claims. The federal district court dismissed the action based on ERISA preemption. Appellant then amended her complaint to add ERISA claims and asked the district court to apply de novo review in its evaluation of her ERISA claims. The court denied the motion and granted summary judgment for Sun Life, concluding that Sun Life's decision to deny benefits was not arbitrary and capricious, and thus complied with ERISA's requirements. The First Circuit Court of Appeals vacated the judgment, holding (1) the safe harbor exception to ERISA did not apply to the policy covering Appellant, and therefore, Appellant's state law claims were preempted; but (2) the benefits denial was subject to a de novo review, rather than the highly deferential "arbitrary and capricious" review prescribed for certain ERISA benefits decisions. Remanded. View "Gross v. Sun Life Assurance Co. of Canada" on Justia Law
Sun Capital Partners III, LP v. New England Teamsters & Trucking Indus. Pension Fund
This case concerned the withdrawal liability for a pro rata share of unfunded vested benefits to a multiemployer pension fund of Scott Brass, Inc. (SBI), a bankrupt company. SBI had withdrawal pension obligations to the multiemployer pension fund (TPF), which sought to impose the obligations on two private equity funds (Plaintiffs). Plaintiffs asserted they were passive investors that indirectly controlled SBI and sought a declaratory judgment against the TPF. The TPF counterclaimed and sought payment of the withdrawal liability at issue. The district court entered summary judgment for Plaintiffs. The First Circuit Court of Appeals affirmed in part, reversed in part, and vacated in part, holding (1) at least one of the private equity funds that operated SBI sufficiently operated and was advantaged by its relationship with SBI, and further factual development was necessary as to the other equity fund; (2) the district court erred in entering summary judgment for Plaintiffs under the "trades or businesses" aspect of a two-part "control group" test under 29 U.S.C. 1301(b)(1); and (3) the district court correctly entered summary judgment for Plaintiffs on TPF's claim of liability on the ground that the funds had engaged in a transaction to evade or avoid withdrawal liability. Remanded. View "Sun Capital Partners III, LP v. New England Teamsters & Trucking Indus. Pension Fund" on Justia Law
Hannington v. Sun Life & Health Ins. Co.
Plaintiff filed this ERISA action against Sun Life and Health Insurance Company (Sun) after Sun reduced his disability payments under an ERISA-qualified plan (Plan) because he was also receiving disability compensation under the Veterans' Benefits Act. The district court entered judgment on the record for Plaintiff. The First Circuit Court of Appeals affirmed, holding (1) because Sun's decision to offset Plaintiff's service-connected disability compensation (VA benefits) was governed entirely by its interpretation of several statutes, the district court ought to have reviewed de novo Sun's determination that Plaintiff's VA benefits were "other income" under the plan; and (2) Plaintiff's VA benefits were not "other income" for purposes of reducing the payment Sun owed Plaintiff under the Plan. View "Hannington v. Sun Life & Health Ins. Co." on Justia Law
Colby v. Union Sec. Ins. Co.
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
Cruz v. Bristol-Myers Squibb Co., PR, Inc.
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
Cameron v. Idearc Media Corp.
Plaintiffs, former directory-advertising sales representatives for Idearc were discharged in 2007. Each was older than 40 and each had at least 18 years of service. Idearc claimed they were let go for poor performance; the employees alleged that the terminations were motivated by age discrimination (Age Discrimination in Employment Act, 29 U.S.C. 621) and a desire to negate pension benefits (Employee Retirement Income Security Act, 29 U.S.C. 1140,). They also advanced a retaliation claim. The district court rejected all of their claims. The First Circuit affirmed, noting the company’s performance-based standards. Idearc’s 2002 collective bargaining agreement authorized Idearc to terminate underperforming employees as specified by the plan. Employees were ranked within six-month periods by "percent net gain," calculated by comparing a salesperson's revenues against the revenue produced by his accounts in the previous year. Idearc was permitted to terminate employees failing 4 out of 7 consecutive semesters, but no more than 7.5 percent of a peer group could be terminated in any given semester. View "Cameron v. Idearc Media Corp." on Justia Law
Scibelli v. Prudential Ins. Co.
Decedent worked for the company from 1982 until 1997, when, at age 52, he was treated for degenerative disc changes, alcohol abuse, and depression. He never returned to work and died in 2008. He was enrolled in his employer's group life, administered by defendant under the Employee Retirement Income Security Act, 29 U.S.C. 1001, was a participant in a long-term disability benefits plan, and had purchased an individual life insurance policy from defendant. He applied for premium waivers under the life insurance policies and received disability benefits under Social Security Disability Insurance and under the employer's plan. Defendant granted a waiver of premiums under the individual policy, but denied a waiver under the group policy. Decedent did not learn about the denial until seven years later. In 2006 and 2008, defendant again denied the application. The estate filed suit in 2010 to recover life insurance benefits and enforce rights under the group policy. The district court granted summary judgment for defendant. The First Circuit reversed, noting defendant's many mistakes in handling the claim and that defendant did not reserve to itself discretion as to interpretation and administration of its plan. Decedent was "totally disabled" for purposes of the plan. View "Scibelli v. Prudential Ins. Co." on Justia Law
Maher v. MA Gen. Hosp.
Plaintiff, an RN, stopped working at the hospital and went on disability only a few months after starting work. Her symptoms were attributed to chronic pancreatitis, chronic pain syndrome or fibromyalgia; she took "impressive amounts of narcotics" to manage her pain, which caused negative side effects. After about five years, the company terminated benefits, finding that she was not totally disabled, as defined by the policy. The district court upheld the termination in a suit under the Employee Retirement Income Security Act, 29 U.S.C. 1132(a)(1)(B). The First Circuit remanded for further review, reasoning that plaintiff's activities, shown on surveillance tapes, and the lack of clinical documentation were overstated. View "Maher v. MA Gen. Hosp." on Justia Law
Ortega Candelaria v. Orthobiologics, LLC
A employee made a series of attempts to obtain benefits under the company's long-term disability policy. A copy of the plan, which he obtained during internal appeals, contained no limitation on filing suit to challenge denials, but did reserve the right to make alterations to the plan. The plan was later amended to include a one-year limitation on bringing suit. Employee did not receive notice of the change. In 2005 the plan issued a final written rejection. In 2008 the employee filed suit under the Employee Retirement Income Security Act, 29 U.S.C. 1109 and 1132. The district court dismissed. The First Circuit reversed. While the plan did not engage in deceptive conduct that would implicate equitable estoppel, equitable tolling applies based on the failure to give notice of the change. The employee was reasonably diligent. View "Ortega Candelaria v. Orthobiologics, LLC" on Justia Law
D&H Therapy Assocs., LLC v. Boston Mut. Life Ins.
The company purchased a disability benefits plan, regulated by the Employee Retirement Income Security Act. A part-owner and employee of the company received benefits for about four years before the insurer terminated benefits because her non-salary income was higher than her salary income had been. The plan defines "pre-disability earnings" as: "your monthly rate of earnings from the employer in effect just prior to the date disability begins" and "basic annual earnings" as the amount reported by the policyholder on a W-2, excluding commissions. The company argued that a provision allowing termination of benefits when "current earnings" reach a percentage of pre-disability earnings referred to earnings from all sources. The district court held that the employee was not entitled to benefits but denied the insurer reimbursement. The First Circuit reversed, in favor of the employee, finding that the insurer's interpretation of the plan was unreasonable.