Justia ERISA Opinion SummariesArticles Posted in US Court of Appeals for the District of Columbia Circuit
Fisher v. Pension Benefit Guaranty Corp.
The DC Circuit affirmed the district court's grant of summary judgment to PBGC, concluding that 29 C.F.R. 4044.4(b) is valid and that the PBGC Appeals Board reasonably applied section 4044.4(b) to deny appellant's lumpsum request. The court also concluded that, because fiduciaries must act in accordance with the terms of plan documents only "insofar as such documents and instruments are consistent with the provisions of" the Employee Retirement Income Security Act of 1974 (ERISA), Penn Traffic fulfilled its fiduciary duties by denying appellant's request in compliance with section 4044.4(b). Therefore, the court need not address appellant's contentions that Penn Traffic's handling of his lumpsum request was inconsistent with the Plan's terms. View "Fisher v. Pension Benefit Guaranty Corp." on Justia Law
Wilcox v. Georgetown University
Participants in Georgetown University retirement plans sued the University and individual plan fiduciaries, seeking to bring individual and representative class action claims for breach of fiduciary duty under the Employee Retirement Income Security Act (ERISA) 29 U.S.C. 1001–1461. They alleged that the plans paid excessive fees for record-keeping services and included investment options that consistently underperformed their benchmarks. In January 2019, the district court dismissed the complaint without prejudice, citing Article III standing as to some aspects of plan management, such as the inclusion of investment options neither plaintiff had selected. Regarding the duty of prudence, the court found that the excessive recordkeeping fees allegations provided no factual support for the assertion that the plans should pay only $35/year per participant. In May, the court denied as untimely their motion for leave to file an amended complaint.The D.C. Circuit vacated. Dismissal of a complaint without prejudice is generally not a final appealable order. Exceptions that apply where the record clearly indicates that the district court has separated itself from the case do not apply to this case. The January Order did not enter a final, appealable judgment; the district court erred when considering the motion to amend the complaint in refusing to apply the Rule 15(a)(2) standard, rather than the more restrictive standards under Rules 59(e) and 60(b). View "Wilcox v. Georgetown University" on Justia Law
Lewis v. Pension Benefit Guaranty Corp.
In 2005, Delta Airlines filed for bankruptcy and stopped contributing to its pilots' pension plan. Delta and the Pension Benefit Guaranty Corporation (PBGC) terminated that Plan, which had insufficient assets to support promised benefit payments, Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1301-1461. Under such circumstances, a trustee collects the remaining assets and makes promised payments according to statutory priorities. PBGC provides additional money from its own funds to make up the difference between those payments and guaranteed benefits. PBGC, the Plan's trustee, determined the Plan had a deficit of over $2.5 billion, almost $800 million of which PBGC guaranteed, and paid estimated benefits. It took six years to finalize benefit determinations. After administrative appeals by the pilots, nearly 1,700 beneficiaries sued to further challenge those determinations, citing the Administrative Procedure Act, 5 U.S.C. 706, and seeking disgorgement, arguing that the Corporation breached its fiduciary duty and controlled Plan assets for a longer period to collect “massive investment returns” rather than timely paying the pilots. The D.C. Circuit reversed the denial of the Corporation’s motion to dismiss the breach of fiduciary duty claim. Recovering the post-termination increase in the value of plan assets is not an available remedy; 29 U.S.C. 1344(c) prevents disgorgement, providing that “[a]ny increase or decrease in the value of the assets of a single-employer plan occurring after the date on which the plan is terminated shall be credited to, or suffered by, the [C]orporation.” View "Lewis v. Pension Benefit Guaranty Corp." on Justia Law
Marcin v. Reliance Standard Life Insurance Co.
Reliance challenged the district court's award of disability benefits to plaintiff under a plan pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., and the amount of benefits owed. The DC Circuit affirmed, holding that plaintiff proved partial disability. In this case, the conflict of interest factor in the standard of review, as well as plaintiff's medical record, lack of full time work, and release to return to work only "as tolerated" convinced the court that she established partial disability. The court explained that, according to the express terms of the Plan, partial disability was equivalent to total disability within the relevant period. View "Marcin v. Reliance Standard Life Insurance Co." on Justia Law