Justia ERISA Opinion SummariesArticles Posted in US Court of Appeals for the Eighth Circuit
York v. Wellmark, Inc.
Plaintiffs filed a putative class action, asserting breach of contract claims under Iowa law and breach of fiduciary duty claims under the Employee Retirement Income Security Act (ERISA), based on allegations that Wellmark violated the Patient Protection and Affordable Care Act's (ACA) mandate's cost-sharing and "information and disclosure" requirements. The district court dismissed the information and disclosure claims for failure to state a claim and granted Wellmark summary judgment on the cost-sharing claims.The Eighth Circuit affirmed and held that the district court accurately noted that neither the ACA's statutory mandate nor its implementing regulations requires the disclosure of information -- including a list of providers -- or prohibits "administrative barriers" or "inconsistent guidance." Rather, the mandate provides that group health plans and health insurance issuers "shall, at a minimum provide coverage for and shall not impose any cost sharing requirements for" preventive health services. The court also held that the summary judgment record established that defendant provided plaintiffs qualified, available in-network providers of comprehensive lactation support and consulting services and did not violate the ACA's cost-sharing mandate. View "York v. Wellmark, Inc." on Justia Law
DaPron v. Spire Inc. Retirement Plans Committee
Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA) alleging that the Committee wrongfully denied his disability claim under its Employees' Retirement Plan and breached its fiduciary duty by failing to conduct a full and fair review of his medical records when reconsidering his claim.The Eighth Circuit affirmed the district court's judgment in favor of the Plan, holding that the district court properly found that the Committee did not breach its fiduciary duty by failing to review the medical records. The court rejected defendant's claim that the Committee offered different rationales for denying his claim and held that the Committee's denial letters consistently state that the application was denied as untimely because it was not made before or in connection with plaintiff's separation. View "DaPron v. Spire Inc. Retirement Plans Committee" on Justia Law
Davis v. Washington University in St. Louis
Three retirement-plan participants field suit against WashU for breach of its fiduciary duties under the Employee Retirement Income Security Act (ERISA). The district court dismissed the complaint for failure to state a claim.The court held that plaintiffs sufficiently alleged that fees were too high and that WashU should have negotiated a better deal. The court held that a failure of effort or competence is enough to state a claim for breach of the duty of prudence. In this case, two inferences of mismanagement are plausible from the WashU's failure to offer more institutional shares. However, the court held that plaintiffs' claims that WashU had several underperforming investments in the plan for too long was properly dismissed, because the allegations failed to establish a meaningful benchmark for evaluating the challenged options. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Davis v. Washington University in St. Louis" on Justia Law
Sanzone v. Mercy Health
Plaintiff filed suit against Mercy Health, alleging that Mercy's plan management disregards requirements under the Employee Retirement Income Security Act. Mercy asserted that it does not have to comply with ERISA's requirements because the plan falls under ERISA's church-plan exemption pursuant to 29 U.S.C. 1003(b)(2).The Eighth Circuit held that whether a plan is an ERISA plan is an element of the plaintiff's case and not a jurisdictional inquiry. Therefore, the district court erred in dismissing the case for lack of jurisdiction. The court remanded to the district court to determine whether the deprivation of ERISA protections confers Article III standing, and if so, whether the church-plan exemption violates the Establishment Clause. If there is Article III standing, the state law claims should be reinstated pursuant to the court's supplemental jurisdiction. View "Sanzone v. Mercy Health" on Justia Law
Vigeant v. Meek
Plaintiffs filed a putative class action against former trustees of the Lifetouch Plan, the Board, and Lifetouch, alleging claims under the Employee Retirement Income Security Act (ERISA). The Eighth Circuit affirmed the district court's dismissal of the amended complaint for failure to state a claim. The court held that, because plaintiffs failed to plead a plausible breach of the duty of prudence by the trustee defendants, the district court properly dismissed their duty to monitor claims against the Board and Lifetouch because those claims cannot survive without a sufficiently pled theory of an underlying breach. View "Vigeant v. Meek" on Justia Law
Mitchell v. Blue Cross Blue Shield of North Dakota
Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), alleging that Blue Cross abused its discretion by partially denying their claim for air-ambulance benefits under an employee health plan. The district court granted summary judgment in part to Blue Cross and in part to plaintiffs.The Eighth Circuit held that the wrongful denial of plan benefits breaches the parties' contract and deprives the participant of the benefit of their bargain. Therefore, this constitutes an injury to the participant—even if the benefits are assigned to a third party. In this case, plaintiffs satisfied the injury-in-fact component of constitutional standing. The court also held that plaintiffs had statutory standing, because they have alleged a colorable claim that Blue Cross unreasonably prevented the "Allowed Charge" for "Ambulance Services" and denied their claim for benefits based on that interpretation.On the merits, the court held that Blue Cross did not abuse its discretion by partially denying plaintiffs' claim. The court wrote that the plan gave Blue Cross broad discretion to determine the "Allowed Charge" for air-ambulance services, and Blue Cross has adopted a consistent interpretation, tied to an external benchmark, which is compatible with both the plan's language and its purpose. Finally, the court held that Blue Cross did not abuse its discretion in interpreting the "medical supply" fee language. View "Mitchell v. Blue Cross Blue Shield of North Dakota" on Justia Law
Johnson v. Charps Welding & Fabricating, Inc.
Trustees of three employee benefit funds filed suit against Charps and others, alleging that defendants breached collective bargaining agreements by not contributing to the employee benefit funds for work performed by the affiliates, in violation of the Employee Retirement Income Security Act (ERISA). The district court granted summary judgment to defendants, awarding them attorney's fees and costs.The Eighth Circuit held that defendants did not owe contributions for the affiliates' work where the trustees have not shown a genuine issue that the defendant companies formed a relationship of alter ego, joint venture, or joint enterprise. Furthermore, the collective bargaining agreements did not require defendants to contribute for the work of Charps' affiliates. The court also held that the trustees did not meet their burden in opposing summary judgment on their claim that the district court failed to address Charps' liability for contributions based on its own employees' work, and the district court did not abuse its discretion in denying, as duplicative, the trustees' motion to compel production of the spreadsheets.Accordingly, the court affirmed the judgment in 18-3007, but reversed and remanded in 19-1206. On remand, the district court should award costs that are taxable under 28 U.S.C. 1821 and 1920. In regard to the nontaxable costs, the district court may determine whether they may be awarded as attorney's fees. View "Johnson v. Charps Welding & Fabricating, Inc." on Justia Law
Rozo v. Principal Life Insurance Co.
The Eighth Circuit reversed the district court's grant of summary judgment to Principal in an action brought under the Employee Retirement Income Security Act (ERISA). The court held that Principal is a fiduciary when its sets the Composite Crediting Rate (CCR) for its 401(k) retirement plan. Under the two-part test in Teets v. Great-West Life & Annuity Ins. Co., 921 F.3d 1200 (10th Cir. 2019), the court held that Principal's setting of the CCR does not conform to a specific term of its contract with the employer plan, and the plan sponsors here did not have the unimpeded ability to reject the service provider's action or terminate the relationship. Accordingly, the court reversed and remanded for further proceedings. View "Rozo v. Principal Life Insurance Co." on Justia Law
Miller v. Hartford Life & Accident Insurance Co.
The Eighth Circuit affirmed the district court's dismissal of plaintiff's complaint against Hartford Life in an Employee Retirement Income Security Act (ERISA) action. The court held that the district court did not err by dismissing the complaint with prejudice, because substantial evidence supported Hartford Life's decision to terminate benefits based on exhaustion of mental illness benefits and the lack of a disabling physical condition. In this case, Hartford Life found no disabling physical condition or mental illness based on the medical evidence and the opinions of treating, examining, and reviewing physicians. View "Miller v. Hartford Life & Accident Insurance Co." on Justia Law
Jones v. Aetna Life Insurance Co.
When Aetna terminated plaintiff's disability benefits, she filed an Employee Retirement Income Security Act suit. The Eighth Circuit affirmed the district court's judgment on remand, holding that the district court did not err by determining that plaintiff failed to administratively exhaust her breach of fiduciary duty claim. View "Jones v. Aetna Life Insurance Co." on Justia Law