Articles Posted in US Court of Appeals for the Eighth Circuit

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Plaintiffs filed suit against defendants, challenging the management of a defined benefit pension plan under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs alleged that defendants violated sections 404, 405, and 406 of ERISA by breaching their fiduciary obligations and causing the Plan to engage in prohibited transactions with a U.S. Bank subsidiary, FAF Advisors. The Eighth Circuit affirmed the district court's dismissal of the case as moot based on the Plan's overfunded status where there was no actual or imminent injury to the Plan itself that caused injury to plaintiffs' interests; dismissal of the Equities Strategy claim on statute-of-limitations and pleading grounds; and dismissal of plaintiffs' motion for attorneys' fees and costs. View "Thole v. U.S. Bank" on Justia Law

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Twin City filed suit seeking to recover unpaid fringe-benefit contributions allegedly due under a collective bargaining agreement (CBA). The district court granted summary judgment for the Association on the ground that WQS was precluded by a previous lawsuit from disputing liability for the contributions as an alter ego of a signatory of the agreement. The Eighth Circuit affirmed the district court's determination that WQS was liable for the unpaid fringe-benefit contributions where all of the elements required to apply issue preclusion were present. The court held that the Association has a right to collect contributions under the CBA, but that two categories of damages were not authorized by the Employee Retirement and Income Security Act, 29 U.S.C. 1132, 1145, and that the award should be reduced accordingly. The court also upheld the district court's grant of injunctive relief. The court remanded for the district court to exclude contributions due to the Working Fee and Industry Fund from the damages award, and to reduce the award of interest accordingly. View "Twin City Pipe Trades Service Assoc. v. Wenner Quality Services, Inc." on Justia Law

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The Fund filed suit against defendants under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(3), alleging that it had a right to a portion of a negligence settlement attributable to medical expenses. The Eighth Circuit affirmed the district court's grant of summary judgment for the Fund, considering defendants' admissions that the settlement agreements included the claim for medical expenses. Therefore, the Fund was entitled to whatever was recovered for medical expenses in the settlement action. View "Mackey v. Johnson" on Justia Law

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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