Justia ERISA Opinion SummariesArticles Posted in US Court of Appeals for the Eighth Circuit
Marshall v. Anderson Excavating & Wrecking
Plaintiffs filed suit against Anderson Excavating under 29 U.S.C. 185(a), 29 U.S.C. 1132, and 29 U.S.C. 1145, requesting that the district court order Anderson Excavating to pay the contributions it allegedly owed to the Welfare Plan and Pension Plan, along with interest, liquidated damages, and attorneys' fees and costs. The Eighth Circuit held that the district court erred in determining damages for unpaid contributions, prejudgment interest, liquidated damages, and attorneys' fees; the district court legally erred in applying the alter ego doctrine to justify an award of unpaid contributions for an alleged employee's work; and thus the court reversed the judgment of the district court and remanded for further proceedings. View "Marshall v. Anderson Excavating & Wrecking" on Justia Law
Meiners v. Wells Fargo & Co.
The Eighth Circuit affirmed the district court's dismissal of plaintiff's complaint for failure to state a claim. Plaintiff alleged that his former employer, Wells Fargo, breached their fiduciary duty under the Employment Retirement Income Security Act (ERISA). The court held that the district court correctly determined that plaintiff's omission of any meaningful benchmark in his complaint meant that he failed to allege any facts showing the Wells Fargo Target Date Funds were an imprudent choice. In this case, plaintiff did not plead that the Funds were underperforming and his conclusory allegations of bad conduct did not save the complaint from its deficient pleading. Therefore, plaintiff failed to state a claim for relief under ERISA. View "Meiners v. Wells Fargo & Co." on Justia Law
Moore v. Apple Central, LLC
Apple acquired the Rogers, Arkansas Applebee’s Neighborhood Grill & Bar, and offered its employees a benefits package that included Guardian life insurance. Megan Moore alleged that employee James Moore enrolled for “basic life coverage” equal to 150% of his $62,000 annual salary, and “voluntary term life coverage” equal to five times his salary ($310,000). Megan, his designated primary beneficiary, alleged that Apple withheld premiums for the voluntary coverage from Moore’s salary until he died in 2013, but “failed to pay over those premiums” and to forward Moore’s application to Guardian. Mehan filed a proof of claim with Guardian, which indicated that premiums had not been received. Megan sued, asserting state law claims for breach of contract, negligence, breach of fiduciary duty, and promissory estoppel and seeks actual and punitive damages. The Eighth Circuit affirmed the dismissal of the complaint. The Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a), preempted all of Moore’s claims. “Allowing state law claims premised on the existence of an ERISA plan to proceed against the plan administrator would affect relations between primary ERISA entities and impact the administration of the plan.” The court noted that Moore's Second Amended Complaint alleging claims under ERISA, 29 U.S.C. 1132(a)(1)(B) and (a)(3) for wrongful denial of plan benefits, breach of fiduciary duty, and equitable estoppel, remains pending. View "Moore v. Apple Central, LLC" on Justia Law
Pharmaceutical Care Management v. Rutledge
Act 900, Arkansas Code Annotated 17-92-507, an amendment to the state's then-existing maximum allowable cost (MAC) law that governed the conduct of pharmacy benefits managers, was preempted by the Employee Retirement Income Security Act (ERISA) and Medicare Part D statutes. The Eighth Circuit affirmed the district court's ERISA ruling in this case, but reversed the Medicare Part D ruling. The court remanded for entry of judgment for PCMA. View "Pharmaceutical Care Management v. Rutledge" on Justia Law
Wengert v. Rajendran
The Eighth Circuit affirmed the district court's grant of summary judgment against plaintiff in an action seeking funds from her husband's trust that was transferred from an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001-1461, plan. The husband had requested the "Accrued Benefit" amount from his ERISA employee-benefit plan be transferred to his trust days before he passed away. Applying an abuse of discretion standard to this case, the court held that the plan administrative committee reasonably explained its interpretation and relied on substantial evidence to deny plaintiff's claim. Therefore, the committee did not abuse its discretion when it determined that the relevant inquiry was not when funds were received by a participant, but rather when funds were transferred out of the plan. View "Wengert v. Rajendran" on Justia Law
Boyd v. ConAgra Foods, Inc.
The Eighth Circuit affirmed the district court's grant of summary judgment in favor of ConAgra in an action seeking to recover severance benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that ConAgra's financial conflict of interest was still a relevant factor the court considered in determining whether ConAgra abused its discretion in denying plaintiff's claim; ConAgra did not abuse its discretion in determining that plaintiff lacked good reason to self-terminate; and because ConAgra's decision was reasonable, ConAgra did not abuse its discretion in denying plaintiff's claim for benefits. Furthermore, ConAgra did not breach its fiduciary duty to plaintiff by misstating or omitting certain material information when communicating with him. Finally, the court held that plaintiff's claims were not frivolous and affirmed the award of attorney's fees incurred by plaintiff. View "Boyd v. ConAgra Foods, Inc." on Justia Law
Ibson v. United Healthcare Services
Plaintiff filed suit against UHS under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132, seeking to recover unpaid benefits. The Eighth Circuit held that plaintiff could not bring claims for benefits due to her husband in her personal capacity, but rather, a legal representative of her husband's estate must bring the claim. Furthermore, plaintiff could not bring a section 1132(a)(3)(B) claim in equity. However, a restitutionary claim for premiums she paid under section 1132(a)(3)(B) was potentially available to her if there was a plan violation. The court remanded to the district court to determine initially if there was such a plan violation and, if so, whether restitution of plaintiff's premiums was "appropriate equitable relief" under section 1132(a)(3)(B). The court also held that the district court did not err in determining that UHS was not the plan administrator and plaintiff's breach of contract claim was preempted by ERISA. View "Ibson v. United Healthcare Services" on Justia Law
Thole v. U.S. Bank
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
Twin City Pipe Trades Service Assoc. v. Wenner Quality Services, Inc.
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
Mackey v. Johnson
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