Justia ERISA Opinion Summaries

The Eighth Circuit affirmed the district court's order holding USAble Life did not abuse its discretion in denying plaintiff's claim for disability benefits under the Employee Retirement Income Security Act. The court rejected plaintiff's claim that the court cannot use an abuse of discretion standard in reviewing the denial of her claim because an Arkansas regulation (Rule 101) prohibits the inclusion of discretionary clauses in insurance contracts. Rather, the court concluded that an abuse of discretion is the appropriate standard of review or USAble Life's denial of plaintiff's claim.The court also rejected plaintiff's arguments that the insurer had a conflict of interest or breached its fiduciary duty. The court concluded that USAble Life did not abuse its discretion in its interpretation of the policy or use of an in-house nurse to review, and that substantial evidence supports USAble Life's denial of plaintiff's claim. Finally, there is no support in the record for plaintiff's position that a radiculopathy diagnosis, absent a finding of disability, entitles her to benefits under the policy. View "Roebuck v. USAble Life" on Justia Law

Central Valley filed suit against various defendants who either marketed or administered self-funded health care plans, alleging that defendants breached various fiduciary duties and engaged in various prohibited transactions in violation of the Employee Retirement Income Security Act of 1974 (ERISA).The Eighth Circuit affirmed the district court's grant of summary judgment for defendants. In regard to the 2015 health care plan, the court held that because Central Valley made the final payment decisions, AMPS and TBG did not have discretion over their compensation and were not fiduciaries. In regard to the 2016 health care plan, the court held that because none of Central Valley's allegations pertain to CDS's fiduciary duty of making benefit determinations on hospital and facility claims, Central Valley’s fiduciary duty claim against CDS fails. Furthermore, TBG, AMPS, and CDS did not act with discretion with respect to compensation, and thus no defendant became a fiduciary. Finally, the court rejected Central Valley's prohibited transactions claim. The court also affirmed the district court's award of attorney fees, holding that the district court properly balanced the Westerhaus factors and did not abuse its discretion in awarding defendants attorney's fees. View "Central Valley Ag Cooperative v. Leonard" on Justia Law

The Eighth Circuit reversed the district court's order requiring the Meadowvale Dairy Employee Benefit Plan to pay benefits and attorney's fees to Avera under the Employee Retirement Income Security Act of 1974 (ERISA). Avera alleged that the benefits at issue were due to a former employee of Meadowvale who received care at a hospital operated by Avera.The court held that, although the beneficiary assigned any and all causes of action to Avera, he never had a cause of action against the Plan. Therefore, Avera may not proceed against the Plan under ERISA as an assignee of a beneficiary or otherwise. In this case, after Meadowvale rescinded the beneficiary's coverage under the Plan, neither the employee nor an authorized representative of his exhausted internal remedies to challenge the decision. View "McKennan v. Meadowvale Dairy Employee Benefit Plan" on Justia Law

The Eighth Circuit vacated the district court's grant of summary judgment in favor of the plan beneficiary in an action arising under the Employee Retirement Income Security Act (ERISA). The court held that the district court erred in reviewing Reliance's denial of long-term disability benefits de novo rather than for an abuse of discretion. The court explained that the administrator's decisional delay on appeal does not in and of itself trigger de novo review. Rather, under circuit law, de novo review is not triggered in this context unless the administrator wholly fails "to act on an appeal" and that failure "raises serious doubts about the result reached by the plan administrator" in its initial denial. The court remanded for the district court to review Reliance's benefits decision for an abuse of discretion. View "McIntyre v. Reliance Standard Life Insurance Co." on Justia Law

PCMA filed suit claiming that the Employee Retirement Income Security Act of 1974 (ERISA) and the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (Medicare Part D), preempt two sections of the North Dakota Century Code regulating the relationship between pharmacies, pharmacy benefits managers (PBMs), and other third parties that finance personal health services. The district court determined that only one provision in the legislation was preempted by Medicare Part D and entered judgment in favor of North Dakota on the remainder of PCMA's claims.The Eighth Circuit held that it need not address the "connection with" element of the analysis because the legislation is preempted due to its impermissible "reference to" ERISA plans. In this case, the legislation is preempted because its references to "third-party payers" and "plan sponsors" impermissibly relate to ERISA benefit plans. Therefore, the court held that the North Dakota legislation is preempted because it "relates to" ERISA plans "by regulating the conduct of PBMs administering or managing pharmacy benefits." Finally, the court held that North Dakota waived its savings clause argument. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Pharmaceutical Care Management Ass'n v. Tufte" on Justia Law

Plaintiffs, participants in Target's employee stock ownership plan (ESOP), filed suit against Target and its senior executives, alleging violations of the Employee Retirement Income Security Act (ERISA).The Eighth Circuit affirmed the district court's dismissal of the claims, holding that plaintiffs failed to show that the fiduciaries breached their duty of prudence. In regard to plaintiffs' proposed alternative actions, the court held that Target could not have implemented a purchase freeze without inevitable disclosure and a reasonably prudent fiduciary could still believe disclosure was the more dangerous route than the route taken. The court also held that plaintiffs failed to show that the fiduciaries violated the duty of loyalty in administering the plan because of their potential conflicts where plaintiffs point to nothing more than the tension inherent in the fiduciaries' dual roles as ERISA fiduciaries and Target officers. Plaintiffs also failed to show that the fiduciaries breached the duty of loyalty by making misleading statements to Plan participants because they failed to allege that the fiduciaries knew they were making untruthful statements in their disclosures and to specify which statements were untrue. Finally, plaintiffs' claim that Target's CEOs breached their duty to monitor the other ERISA fiduciaries cannot survive without an underlying breach. View "Dormani v. Target Corp." on Justia Law

The Eighth Circuit affirmed the district court's order dismissing plaintiffs' second amended complaint brought under sections 409 and 502 of the Employee Retirement Income Security Act (ERISA), against Wells Fargo and fiduciaries of Wells Fargo's 401(k) plan. This appeal arose out of the unauthorized-accounts scandal at Wells Fargo where Wells Fargo pressured and induced thousands of its employees to engage in widespread unlawful and unethical sales practices.The court held that the district court did not err in finding that plaintiffs have failed to plausibly plead that a prudent fiduciary in defendants' position could not have concluded that earlier disclosure of negative information would do more harm than good to the fund. The court also held that the district court did not err in holding that plaintiffs have failed to sufficiently plead a claim of breach of the duty of loyalty. In this case, neither of plaintiffs' claims for failure to disclose material information to plan participants about Wells Fargo's sale practices and conflicts of interests and actions of self-interest sufficiently alleged a plausible inference that defendants breached their duty. View "Allen v. Wells Fargo & Co." on Justia Law

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

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

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