Justia ERISA Opinion Summaries

The Secretary filed suit alleging that defendants breached their fiduciary duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., when acting as trustees for an Employee Stock Ownership Plan (ESOP). In a three year period, BAI's owner Herbert C. Bruister sold 100% of his BAI shares to BAI's employees through a series of transactions. Two plan participants, Rader and Sealy, filed suit raising generally the same claims as the Secretary and seeking relief on behalf of the ESOP as a whole. The court concluded that Sealy has standing to sue on behalf of the ESOP; the district court applied the law correctly and did not clearly err in finding that Bruister was a fiduciary of the ESOP; defendants breached the duties of loyalty and prudence in their conduct with respect to the stock sales and engaged in prohibited transactions; the district court did not abuse its discretion by denying rescission of the BAI stock sales but granting equitable restitution in the amount the ESOP overpaid; the district court did not clearly err in holding BFLLC jointly and severally liable with the other defendants; the district court’s award and calculation of prejudgment interest were not an abuse of discretion; under the totality of circumstances, the district court did not abuse its discretion in barring defendants from serving as ERISA fiduciaries in the future; and, to alleviate any misconception and avert double recovery, the court modified the concurrent judgments in each consolidated case into a single judgment that disposes of them together. Accordingly, the court affirmed the judgment, but modified its concurrent judgments. View "Perez v. Bruister" on Justia Law

After Prudential denied plaintiff's claim for long-term disability benefits, plaintiff subsequently filed suit against Prudential under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The district court granted summary judgment for Prudential. Because the Plan expressly grants Prudential discretionary authority, the court held that the district court correctly reviewed Prudential’s denial for an abuse of discretion. As such, the court's de novo review of the district court's summary judgment ruling will also apply the abuse of discretion standard. The court concluded that, in light of this record, plaintiff has failed to raise a genuine dispute of material fact that Prudential abused its discretion in denying his claim for long-term disability benefits. Prudential acknowledged that while plaintiff does have depression and anxiety, typically depression and anxiety do not cause large changes in cognitive function, and in plaintiff's case, there is no evidence of valid cognitive impairment from any source. Accordingly, the court affirmed the judgment. View "Burell v. Prudential Ins. Co." on Justia Law

Plaintiff filed suit against Aetna and Hewlett Packard to recover benefits as the beneficiary of her husband’s group life insurance plan under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)(B). On appeal, plaintiff challenged the district court's final judgment affirming the decision of the ERISA plan administrator to deny benefits. The court concluded that plaintiff has not provided evidence that suggests that the method by which Aetna made its determination in her case was procedurally unreasonable; the court rejected plaintiff's claim that Aetna’s conflict should be given greater weight in the district court’s analysis because it has a history of biased claims administration; and evidence is sufficient to permit a reasonable mind to reach the conclusion that the husband's fall was due to or contributed to by illness. The court further stated that, even accounting for Aetna’s conflict of interest as both insurer and plan administrator, Aetna did not abuse its discretion in determining that the husband's fall was not a covered “accident” under the terms of the Policy, negating recovery under the Policy. Because Aetna's denial of plaintiff's claim was not an abuse of discretion, the court affirmed the judgment. View "Hagen v. Aetna Ins. Co." on Justia Law