Justia ERISA Opinion Summaries

Plaintiff filed claims alleging breach of contract and claims under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., against BAH and others. Under California law, a breach of a written contract must be brought within four years of the date of the alleged breach, Cal. Civ. Proc. Code 337. The court concluded that plaintiff's cause of action accrued in September 2003 and the filing of his complaint was untimely. Therefore, plaintiff's breach of contract claim is time barred. The court also concluded that the district court did not abuse its discretion by denying plaintiff a third opportunity to amend his complaint. Finally, the court held that the employer’s stock rights plan did not qualify as an employee pension benefit plan subject to ERISA under 29 U.S.C. 1002(2)(A) because its primary purpose was not to provide deferred compensation or other retirement benefits. Because, in this case, the stock rights plan was not designed or intended to provide retirement or deferred income, it is not covered by ERISA. Accordingly, the court affirmed the judgment. View "Rich v. Shrader" on Justia Law

Plaintiffs, former employees of Golden Eagle, filed a class action against Liberty Mutual for violating the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs alleged that when Liberty Mutual purchased Golden Eagle, Liberty Mutual told plaintiffs that they would receive past service credit for the time they worked with Golden Eagle under Liberty Mutual’s retirement plan. The district court granted summary judgment to Liberty Mutual. The court concluded that plaintiffs cannot receive benefits for past service credit with Golden Eagle under the terms of the retirement plan where the district court applied the correct abuse of discretion standard, and Liberty Mutual's interpretation of the plan was reasonable. The court also concluded that plaintiffs are not barred from bringing simultaneous claims under section 1132(a)(3) and 1132(a)(1)(B). In Varity Corp. v. Howe, equitable relief under section 1132(a)(3) is not available if section 1132(a)(1)(B) provides an adequate remedy. In CIGNA Corp. v. Amara, section 1132(a)(3) authorized equitable relief in the form of plan reformation, even though plaintiffs also claimed relief under section 1132(a)(1)(B). Applying Amara’s conclusion that a plaintiff may seek relief under both section 1132(a)(1)(B) and section 1132(a)(3) does not contravene the ruling in Varity. The court further concluded that Liberty Mutual failed to notify plaintiffs in its summary plan descriptions that past service credit with Golden Eagle would not count for benefits accrual, but plaintiffs did not prove harm or reliance on the summary plan descriptions. Finally, the class certification was appropriate. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Moyle v. Liberty Mut. Ret. Benefit Plan" on Justia Law

Bruce Barton filed suit against ADT under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1132, seeking claims related to his request for pension benefits. On appeal, Barton challenges the district court's conclusion that the Plan Administrator did not abuse its discretion in denying Barton’s request for pension benefits. The court concluded that the district court incorrectly placed the burden of proof on Barton for matters within defendants’ control. The court held that where a claimant has made a prima facie case that he is entitled to a pension benefit but lacks access to the key information about corporate structure or hours worked needed to substantiate his claim and the defendant controls such information, the burden shifts to the defendant to produce this information. The district court correctly held that to recover statutory penalties based on a plan administrator’s refusal to comply with ERISA’s disclosure obligations, a plaintiff must qualify as a plan participant. The court reversed and remanded for the district court to apply the now-clarified burden of proof in this case. View "Estate of Barton v. ADT" on Justia Law