Justia ERISA Opinion SummariesArticles Posted in U.S. 8th Circuit Court of Appeals
Riley v. Sun Life and Health Ins., et al.
Appellant appealed the district court's grant of summary judgment in favor of Sun Life in an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., benefits case. At issue was whether Sun Life was entitled to offset from appellant's employer-provided long-term disability benefits the amount that appellant received in Department of Veterans Affairs (VA) benefits each month. The court held that VA benefits, for a wartime service-related disability, as a matter of statutory construction, did not derive from an act that was "similar to" the SSA or RRA, which were both federal insurance programs based upon employment and the amount of an award under their terms depended upon how much had been paid in. Accordingly, the court reversed and remanded to the district court with directions to enter judgment in favor of appellant. View "Riley v. Sun Life and Health Ins., et al." on Justia Law
Sturge v. Northwest Airlines, Inc.
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
Dakota, MN & Eastern R.R. Corp. v. Schieffer
Defendant entered into an Employment Agreement with his employer before the employer entered into a merger. After defendant was terminated by his employer and post-merger disputes arose as to the amounts his employer owed him, defendant filed a demand for arbitration under the Employment Agreement's arbitration provision. The employer commenced this action to enjoin the arbitration as preempted by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. The employer alleged federal question jurisdiction under 28 U.S.C. 1331 because the severance dispute "arises out of an [ERISA] employee benefit plan" and therefore state law claims were preempted, and supplemental jurisdiction under 18 U.S.C. 1367 over non-ERISA claims. The court considered ERISA's statutory language, purpose, and historical context and held that an individual contract providing severance benefits to a single executive employee was not an ERISA employee welfare benefit plan within the meaning of section 1002(1). The court also held that ERISA preempted state laws that "relate to" an employee benefit plan. Consequently, further questions arose because the Employment Agreement included two provisions that could "relate" to the Employment Agreement to other programs of the employer that were ERISA plans. As neither parties nor the district court considered this jurisdictional issue, the court remanded for further proceedings. View "Dakota, MN & Eastern R.R. Corp. v. Schieffer" on Justia Law
Angevine v. Anheuser-Busch Co. Pension Plan, et al.
Plaintiff appealed from the district court's dismissal of his claim for benefits under ERISA, 29 U.S.C. 1001 et seq., where the district court held that he failed to exhaust his administrative remedies. The court held that because plaintiff sought either current or future benefits, the plan provided an administrative procedure for his claim. The facts alleged in plaintiff's complaint showed neither futility nor the lack of an administrative remedy and therefore, the court concluded that he was required to exhaust his administrative remedies under the plan before he could bring a civil action in federal court. View "Angevine v. Anheuser-Busch Co. Pension Plan, et al." on Justia Law
Green v. Union Security Ins. Co.
After defendant denied plaintiff's claim for long-term disability benefits (LTD benefits), where plaintiff suffered from fibromyalgia, plaintiff filed a complaint against defendant pursuant to ERISA, 29 U.S.C. 1000 et seq. At issue was whether the district court properly granted summary judgment in plaintiff's favor finding that defendant had abused its discretion in denying benefits to plaintiff. The court held that the district court improperly determined that defendant abused its discretion when it ultimately denied the LTD benefits claim. Based on the record, there was more than a scintilla of evidence supporting defendant's conclusion that plaintiff's condition did not render him "disabled" under the policy's any occupation definition and defendant's decision was supported by substantial evidence, where a reasonable person could have reached a similar decision. The court also held that the fact that defendant operated under a structural conflict of interest, as both plan administrator and insurer, did not warrant a finding that defendant abused its discretion in denying plaintiff's claim. Accordingly, the court reversed summary judgment and remanded for further proceedings. View "Green v. Union Security Ins. Co." on Justia Law
River v. Edward D. Jones Co., et al.
Appellant, the named beneficiary of an accident benefits plan that her husband obtained through his employer, brought suit under ERISA, 29 U.S.C. 1001 et seq., alleging that the plan administrator, Metropolitan Life Insurance (Metlife), abused its discretion in determining that her husband was intoxicated at the time of the accident and denying coverage. At issue was whether the district court properly granted summary judgment to Metlife because Metlife's interpretation of the relevant policies was arbitrary and capricious and not supported by substantial evidence. The court held that Metlife did not abuse its discretion as plan administrator when it denied benefits based on the general exclusion for intoxication that appeared in the certificate of insurance. The court also held that the toxicology report, which concluded that the husband's blood alcohol level was above the state limit, constituted evidence that a reasonable mind might accept as adequate to support a conclusion and therefore, satisfied the substantial evidence standard. The court also held that because it agreed with the district court's conclusion that the denial of benefits was justified in light of the intoxication conclusion, it need not address Metlife's assertion that the husband's death was not accidental because it was reasonably foreseeable or, alternatively, the result of intentional self-inflicted injury. Accordingly, summary judgment was affirmed. View "River v. Edward D. Jones Co., et al." on Justia Law
Newspaper Guild of St. Louis v. St. Louis Post Dispatch, LLC
Defendant appealed from the district court's grant of summary judgment in favor of plaintiff, compelling arbitration of a dispute related to healthcare benefits under an expired collective bargaining agreement. At issue was whether the district court erred in granting plaintiff's motion for summary judgment and issuing an order compelling the arbitration. The court reversed and held that the district court erred in granting summary judgment and compelling arbitration where both parties vigorously disputed issues of both law and fact, including whether the 1994 agreement was ambiguous and whether the summary plan descriptions constituted an intrinsic or extrinsic evidence of the parties' intent. The parties also point to various other extrinsic evidence and vehemently disagree as to whether the bargained for fully-paid health insurance premiums for life or just for the term of the agreement. Under these circumstances, the court held that the question of whether the right to fully-paid premiums vested under the 1994 agreement was best decided in the first instance by the district court and therefore, remanded for further proceedings. View "Newspaper Guild of St. Louis v. St. Louis Post Dispatch, LLC" on Justia Law