Justia ERISA Opinion SummariesArticles Posted in U.S. 9th Circuit Court of Appeals
Tapley v. Locals 302 and 612
Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., after the Trustees' of their pension plan determined that plaintiffs' respective post-retirement jobs as traffic flagger and snow plow operator fell into the same "job classification" as their former union jobs as skilled mechanics. Therefore, plaintiffs were precluded from working these jobs if they wanted to collect retirement benefits. The court concluded that common sense strongly suggested that a position flagging traffic or plowing snow was not in the same "job classification" as a skilled mechanic repairing heavy equipment utilizing special skills acquired over a long career. The court reversed the district court's judgment because it was unable to see how any sensible application of the skills and duties test to the established facts could support the Trustees' conclusion. Accordingly, the court reversed the judgment. View "Tapley v. Locals 302 and 612" on Justia Law
Carpenters Pension Trust Fund v. Moxley
Debtor was required to make contributions to the Carpenters Pension Trust Fund pursuant to a multiemployer bargaining agreement (the Agreement). When the Agreement expired, debtor no longer was a signatory to a collective bargaining agreement and stopped making payments. The Fund subsequently filed suit because debtor was still doing work covered by the Agreement and was subject to withdrawal liability under 29 U.S.C. 1381. Debtor then filed for bankruptcy and sought a discharge of his debt to the Fund. The Fund filed a complaint under 11 U.S.C. 523(c) to prevent discharge, seeking to establish that the debt qualified as one created via defalcation by a fiduciary under section 523(a)(4). The court concluded that the Bankruptcy Court had jurisdiction to adjudicate the dischargeability of the Fund's claim against debtor; debtor was not a fiduciary of the Fund because the unpaid withdrawal liability was not an asset of the Fund; and debtor's failure to challenge the withdrawal liability amount in arbitration did not act as a waiver of his right to discharge the debt. Accordingly, the court affirmed the judgment. View "Carpenters Pension Trust Fund v. Moxley" on Justia Law
Harris v. Amgen
Plaintiffs, current and former employees of Amgen and AML, participated in two employer-sponsored pension plans, the Amgen Plan and the AML Plan. The Plans were employee stock-ownership plans that qualified as "eligible individual account plans" (EIAPs) under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1107(d)(3)(A). Plaintiffs filed an ERISA class action against Amgen, AML, and others after the value of Amgen common stock fell, alleging that defendants breached their fiduciary duties under ERISA. The court concluded that defendants were not entitled to a presumption of prudence under Quan v. Computer Sciences Corp., that plaintiffs have stated claims under ERISA in Counts II through VI, and that Amgen was a properly named fiduciary under the Amgen Plan. Therefore, the court reversed the decision of the district court and remanded for further proceedings. View "Harris v. Amgen" on Justia Law
Tibble v. Edison International
Beneficiaries sued Edison under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Beneficiaries claimed that their pension plan had been managed imprudently and in a self-interested fashion. The court rejected both parties' timeliness arguments and affirmed the district court's application of ERISA's six-year limitations period. Because the DOL's interpretation of how the safe harbor functions were consistent with the statutory language, the court concluded that the district court properly decided that section 404(c) of Title I of ERISA did not preclude merits consideration of beneficiaries' claims. The court reserved the question of whether the Ninth Circuit should adopt a rule akin to that articulated in Spano v. Boeing Co. regarding class action certification. On the merits, the court was satisfied that revenue sharing as carried out by Edison did not violate ERISA; Edison did not violate its duty of prudence by including several investment vehicles in the Plan menu; but Edison had been imprudent in deciding to include retail-class shares of three specific mutual funds in the Plan menu. View "Tibble v. Edison International" on Justia Law
Day v. AT&T Disability Income Plan
David Day, an ERISA plan beneficiary, elected to roll over his pension benefits into an individual retirement account (IRA) upon separation from his employer, AT&T. Exercising its discretion, the plan's claims administrator construed Day's lump sum rollover as the equivalent of his having "received" his pension benefits and, according to the terms of AT&T's Disability Income Benefit Plan, reduced Day's long-term disability (LTD) benefits by the amount of the rollover. The district court entered judgment in favor of the plan. The Ninth Circuit Court of Appeals affirmed, holding (1) the administrator reasonably interpreted the plan; (2) AT&T did not breach its fiduciary duties by failing to disclose the possibility that Petitioner's LTD benefits would be reduced by his receipt of pension benefits; and (3) the administrator's actions did not violate the Age Discrimination in Employment Act. View "Day v. AT&T Disability Income Plan" on Justia Law
Bilyeu v. Morgan Stanley Long Term Disability Plan, et al.
Plaintiff appealed the district court's dismissal of her claim challenging the termination of her long-term disability benefits under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1132. Plaintiff challenged the district court's grant of summary judgment in favor of Unum on it's counterclaim for restitution of overpaid benefits. The court held that the district court abused its discretion by dismissing the claim for denial of benefits for failure to exhaust administrative remedies. The exhaustion requirement should have been excused because plaintiff acted reasonably in light of Unum's ambiguous communications and failure to engage in a meaningful dialogue. Accordingly, the court vacated the judgment in favor of Unum on plaintiff's claim for denial of benefits. View "Bilyeu v. Morgan Stanley Long Term Disability Plan, et al." on Justia Law
CGI Technologies and Solutions v. Rose, et al.
Defendant appealed the district court's grant of partial summary judgment in favor of CGI in its action seeking "appropriate equitable relief" under section 502(a)(3) of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. CGI appealed the district court's grant of partial summary judgment in favor of defendant's counsel and codefendant, dismissing the codefendant from the action. CGI also appealed the district court's grant of proportional fees and costs to the codefendant, deducted from CGI's recovery from defendant. The court affirmed the district court's grant of summary judgment in favor of the codefendant, dismissing it from the action. However, because the court saw no indication that in fashioning "appropriate equitable relief" for CGI, the district court did more than interpret the plain terms of the reimbursement provision, and no indication that the district court considered traditional equitable principles in assigning responsibility to CGI for attorneys' fees and costs, the court vacated the judgment in favor of CGI, vacated the judgment that the codefendant deducted fees and costs from CGI's entitlement, and remanded to the district court for further proceedings. View "CGI Technologies and Solutions v. Rose, et al." on Justia Law
Alday, et al. v. Raytheon Co.; Agraves, et al. v. Raytheon Co.
Plaintiffs, employees at a defense plant in Arizona, collectively bargained for the right to receive employer-provided healthcare coverage after they retired. At issue was whether those employees, now retirees, were contractually entitled to receive premium-free healthcare coverage until age 65, or whether the contracts on which the retirees relied as providing that entitlement allowed their prior employer to start charging them for their insurance. The court held that Raytheon expressly agreed to provide 100% company-paid healthcare coverage for eligible retirees; that Raytheon's obligation survived the expectation of the collective bargaining agreements (CBAs); and that Raytheon's agreed-upon obligation could not be unilaterally abrogated by Raytheon, regardless of the rights Raytheon reserved for itself in Plan documents, because the CBAs did not incorporate the Plans' reservation-of-rights provisions with respect to employer contribution issues, as opposed to issues relating to the provision of monetary or in kind benefits for particular medical services. The court further held that the district court did not err in rejecting plaintiffs' claim for punitive and extra-contractual damages. View "Alday, et al. v. Raytheon Co.; Agraves, et al. v. Raytheon Co." on Justia Law
Skinner, et al. v. Northrop Grumman Retirement Plan B, et al.
Plaintiffs appealed summary judgment rejecting their claims under the Employee Retirement Income Security Act of 1974, (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs were employees of Litton and participated in its retirement plan (Litton Plan B). Following corporate mergers and plan modifications, plaintiffs sued the successor corporation and Northrop Plan B, the plan that replaced Litton Plan B under section 502(a)(1)(B) to enforce their understanding of their rights under Northrop Plan B. The court held that summary judgment was appropriate on plaintiffs' claims under section 502(a)(1)(B) and 502(a)(3), rejecting their claims based on reformation and surcharge. View "Skinner, et al. v. Northrop Grumman Retirement Plan B, et al." on Justia Law
Leeson v. Transamerica Disability Income Plan
Plaintiff, a former employee of defendant, filed this action under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1101 et seq., to challenge the termination of his long-term disability benefits. At issue on appeal was whether the district court erroneously relied on Curtis v. Nevada Bonding Corp. to dismiss the case for lack of subject matter jurisdiction. The court agreed with plaintiff that Vaughn v. Bay Environmental Management, Inc. controlled in these circumstances. Whether plaintiff was a participant for purposes of ERISA was a substantive element of his claim, not a prerequisite for subject matter jurisdiction. Therefore, the court vacated the dismissal and remanded for further proceedings because plaintiff asserted a colorable claim that he was a plan participant and satisfied the threshold for establishing subject matter jurisdiction. View "Leeson v. Transamerica Disability Income Plan" on Justia Law