Justia ERISA Opinion Summaries

Articles Posted in U.S. Court of Appeals for the Seventh Circuit

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The Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001, sets minimum funding and vesting requirements, insures benefits through the Pension Benefit Guarantee Corporation and includes reporting, disclosures, and fiduciary responsibilities, but exempts church plans from its requirements. The plaintiffs, former and current employees, have vested claims to benefits under the Advocate retirement plan. Advocate operates Illinois healthcare locations, employing 33,000 people. Advocate maintains a non-contributory, defined-benefit pension plan that covers substantially all of its employees. Advocate is not a church. Its predecessor formed as a 501(c)(3) non-profit corporation from a merger between two health systems—Lutheran General and Evangelical. Advocate is affiliated with the Evangelical Lutheran Church and the United Church of Christ, but it is not owned or financially supported by either church. In contracts, the parties “affirm their ministry in health care and the covenantal relationship they share.” There is no requirement that Advocate employees or patients belong to any particular religious denomination, or uphold any particular beliefs. The Seventh Circuit affirmed that the plan “is not entitled to ERISA’s church plan exemption as a matter of law” because the statutory definition requires a church plan to be established by a church. The court rejected Advocate’s First Amendment arguments. View "Stapleton v. Advocate Health Care Network" on Justia Law

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Plaintiff took early retirement from Union Pacific in 2006 and began receiving his monthly benefit (1,022.94) in 2009. In 2010 he retired from Terminal Railroad. Terminal’s retirement plan, governed by ERISA, provides that “the retirement income benefit payable under this Plan shall be offset by the amount of retirement income payable under any other defined benefit plan … to the extent that the benefit under such other plan or plans is based on Benefit Service taken into account in determining benefits under this Plan.” The Terminal Plan administrator calculated the monthly benefit owed plaintiff for his combined years of service to Terminal and Union Pacific to be $3,725.02, from which it would deduct the monthly benefits payable under the Union Pacific Plan, which it calculated as $2,311.73. The Seventh Circuit reversed the district court’s ruling (under 29 U.S.C. § 1132(a)(1)(B)) in favor of plaintiff. The maximum amount payable under the Union Pacific plan was $2,311.73; plaintiff lost nothing by choosing to receive only $1,022.94, because the expected value of a stream of the monthly receipts was equal to the expected value of a stream of monthly receipts of $2,311.73 received for many fewer months. View "Cocker v. Terminal R.R. Ass'n of St. Louis Pension Plan" on Justia Law

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Several multi-employer health and welfare funds filed this suit under the Employee Retirement Income Security Act seeking approximately $70,000 in alleged delinquent contributions. The assertedly delinquent employer, Con-Tech Carpentry, did not file an answer within the statutory period and was found in default. The district court subsequently entered a judgment in the funds’ favor and awarded damages. Con-Tech subsequently filed a Fed. R. Civ. P. 60(b) motion, which also invoked Fed. R. Civ. P. 55(c). The judge denied the Rule 60(b) motion. The Seventh Circuit affirmed, holding that because Con-Tech made a deliberate decision to disregard the pending suit, there was no reason for the district judge to excuse Con-Tech’s conduct in retrospect. View "Mid-Central Illinois Reg’l v. Con-Tech Carpentry, LLC" on Justia Law