Articles Posted in US Court of Appeals for the Eighth Circuit

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Jacob Plassmeyer incurred medical expenses during a collegiate baseball practice, and his college provided its student athletes insurance with FA. Jacob's father was also insured by the Dakotas, an employee welfare benefit plan, and Jacob was covered under this Employee Retirement Income Security Act (ERISA) plan as a dependent of his father. In this case, the trustees of Dakotas brought this declaratory judgment action against FA under section 502(a)(3) of ERISA, 29 U.S.C. 1132(a)(3), seeking an order enforcing the coordination of benefits (COB) provisions in the Dakotas plan by declaring that FA's policy provided primary coverage of Jacob's claim for medical expenses already incurred. The district court denied FA's motion to dismiss and granted Dakotas' motion for summary judgment. The Eighth Circuit held that a declaratory judgment action to enforce the Dakotas plan as it applied to the claim for benefits was both consistent with the plain language of section 502(a)(3), as construed in light of historical equitable remedies available to trustees; the court agreed with the district court that FA's coverage was primary; but the district court abused its discretion in awarding attorney fees. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Dakotas and Western Minnesota Electrical Industry Health & Welfare Fund v. First Agency, Inc." on Justia Law

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The Eighth Circuit affirmed MetLife's denial of long term disability (LTD) benefits to plaintiff under a group insurance plan sponsored by her former employer pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that plaintiff presented no evidence of factors tending to demonstrate a consequential conflict of interest, or other indicia of biased decision making; the district court did not err by using an abuse of discretion standard of review; and MetLife did not abuse its discretion by denying LTD benefits to plaintiff where it properly considered all medical records, APS reports, comments, and other information submitted by plaintiff and her physicians. View "Cooper v. Metropolitan Life Insurance Co." on Justia Law