Justia ERISA Opinion Summaries

Articles Posted in US Court of Appeals for the Ninth Circuit
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DaVita filed suit alleging that the Amy's Kitchen Employee Benefit Health Plan's dialysis provisions violate the Medicare as Secondary Payer provisions (MSP) of the Social Security Act, the Employee Retirement Income Security Act of 1974 (ERISA), and state law. The district court dismissed the federal claims and declined to exercise supplemental jurisdiction over the state-law claims.Reviewing de novo, the Ninth Circuit affirmed and agreed with the district court's conclusion that the Plan does not violate the MSP because it reimburses at the same rate for all dialysis services, regardless of underlying diagnosis and regardless of Medicare eligibility. The panel also held that DaVita may not bring equitable claims on behalf of Patient 1 under ERISA, because the assignment form the patient signed did not encompass an assignment of equitable claims. View "DaVita Inc. v. Amy's Kitchen, Inc." on Justia Law

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The Ninth Circuit affirmed the district court's grant of summary judgment for defendants in an action brought by plaintiff under the Employee Retirement Income Security Act (ERISA), challenging the denial of health care coverage for out-of-state residential treatment for anorexia nervosa.The panel held that defendants' denial of coverage did not violate the Mental Health Parity and Addiction Equity Act or the California Mental Health Parity Act where the denial of coverage was based solely on the Plan's exclusion of coverage for out-of-state treatment, which applies equally to mental and physical illnesses. In this case, plaintiff, aware of this exclusion, sent her daughter to an out-of-state residential treatment program for anorexia nervosa. The panel concluded that plaintiff has not shown that the Plan's requirement of in-state treatment is applied to mental health conditions, but not to other medical conditions. View "Stone v. UnitedHealthcare Insurance, Co." on Justia Law

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The Ninth Circuit affirmed the district court's order granting summary judgment in favor of defendants in an action under the Employee Retirement Income Security Act (ERISA), alleging that a fiduciary breached its duty to make accurate representations to a beneficiary.The panel first held that defendants did not waive their statute of limitations affirmative defense. The panel applied Intel Corp. Inv. Policy Committee v. Sulyma, 140 S. Ct. 768 (2020), which held that "actual knowledge" requires more than merely a possible inference from ambiguous circumstances, but rather knowledge that is actual. The panel held that the record establishes that the beneficiary had actual knowledge of the alleged breach and failed to bring suit within the three-year statute of limitations prescribed under ERISA. In this case, the district court correctly determined that the beneficiary had actual knowledge of the alleged misrepresentation when he received a letter from defendants regarding the bridging of service under the retirement plan. Therefore, the beneficiary's claim is time-barred. Furthermore, there is no exception for fraudulent concealment that triggers the six-year statute of limitations here. Finally, the panel held that the district court did not abuse its discretion in denying the beneficiary's post-judgment motion for reconsideration. View "Guenther v. Lockheed Martin Corp." on Justia Law

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29 U.S.C. 1132(a)(3) does not authorize an award of attorney's fees incurred during the administrative phase of the Employee Retirement Income Security Act (ERISA) claims process. The Ninth Circuit affirmed the district court's dismissal of an ERISA action brought by plaintiff against MetLife. The district court granted MetLife's motion to dismiss the complaint, agreeing with MetLife that attorney's fees awards are not other appropriate equitable relief under section 1132(a)(3).In Cann v. Carpenters' Pension Trust Fund for Northern California, 989 F.3d 313 (9th Cir. 1993), the panel held that attorney's fees incurred in administrative proceedings are not recoverable under section 1132(g), ERISA's express fee-shifting provision. The panel was obligated to read section 1132(a)(3) in conjunction with section 1132(g). Under the expressio unius canon, section 1132(g)'s silence as to fees incurred in an administrative proceeding gives rise to the inference that section 1132(a)(3) does not authorize such fees. View "Castillo v. Metropolitan Life Insurance Co." on Justia Law

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The Ninth Circuit filed (1) an order granting a request for publication, withdrawing the panel's prior memorandum disposition, and directing the filing of an opinion; and (2) an opinion affirming the district court's grant of summary judgment in favor of plaintiffs in an Employee Retirement Income Security Act (ERISA) class action concerning pension contributions.Amendments 14 and 24 of the fund had the effect of withholding at least $1.00 per hour from all employer contributions. Plaintiff filed a class action against the trustees under ERISA. In a prior appeal, Lehman I, the panel held that the trustees could not keep the $1.00 hourly withholdings they had made pursuant to Amendment 14. The panel affirmed the district court's grant of summary judgment for plaintiff and awarded damages to the class. The panel then remanded for the district court to address Amendment 24. On remand, the district court again granted summary judgment in favor of the class.The panel affirmed the district court's determination that Amendment 24 violated the plain language of Article 5 of the Pacific Coast Pension Plan, which mandated that the Plan collect and transfer all contributions received on behalf of travelers. The panel explained that the trustee's interpretation of Amendment 24 with regard to travelers' contributions was inconsistent with the Plan's own definition of "contribution." View "Lehman v. Nelson" on Justia Law

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The Ninth Circuit held that the district court properly exercised federal jurisdiction and correctly denied plaintiff's remand motion because his state law claims could have been brought as Employee Retirement Income Security Act (ERISA) claims. The panel also held that the district court correctly held that two Hawai'i statutes restricting health insurers' subrogation recovery rights are saved from preemption under ERISA section 514, were not subject to conflict preemption under section 502, and provided the relevant rule of decision in the removed action. Because the parties stipulated that HMAA had no valid lien if the Hawai'i Statutes provided the relevant rule of decision, the panel held that the district court properly entered a final judgment in plaintiff's favor View "Rudel v. Hawai'i Management Alliance Assoc." on Justia Law

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The Ninth Circuit reversed the district court's order denying Schwab's motion to compel arbitration in a class action brought by a former participant in an Employee Retirement Income Security Act (ERISA) retirement plan. Plaintiff alleged that defendants violated ERISA and breached their fiduciary duties by including Schwab-affiliated investment funds in the Plan—despite the funds' poor performance—to generate fees for Schwab and its affiliates.In light of the Supreme Court's intervening case law, the panel held that its holding in Amaro v. Continental Can Co., 724 F.2d 747 (9th Cir. 1984), that ERISA claims were not arbitrable, was no longer good law. The panel held that the holding in American Express Co. v. Italian Colors Restaurant, 570 U.S. 228 (2013), that federal statutory claims are generally arbitrable and arbitrators can competently interpret and apply federal statutes, was irreconcilable with Amaro. Accordingly, the court remanded. View "Dorman v. The Charles Schwab Corp." on Justia Law

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The Ninth Circuit affirmed the district court's grant of summary judgment in an Employee Retirement Income Security Act (ERISA) action challenging the denial of plaintiff's request for early retirement benefits. Plaintiff argued that the Board incorrectly interpreted the Plan to deny his application for benefits.The panel held that any procedural irregularities in the Board's actions were minor and, at most, the Board's actions weigh only slightly and weakly in favor of holding that an abuse of discretion occurred here. The panel also held that the Board did not abuse its discretion by interpreting "performance of services in any capacity in the Electrical Industry" to include working for the union. In this case, in light of Tapley v. Locals 302 & 612 of Int'l Union of Operating Eng'rs-Emp'rs Const. Indus. Ret. Plan, the panel held that the Board's interpretation did not clearly conflict with the Plan's language; did not render any other Plan provision nugatory; and did not lack a rational nexus to the Plan's purpose. Therefore, the Board's interpretation of the Plan was reasonable. View "O'Rourke v. Northern California Electrical Workers Pension Plan" on Justia Law

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The DOL brought suit under the Employee Retirement Income Security Act (ERISA) for breach of fiduciary duties and self-dealing by City National in administering City National's employee profit-sharing plan. The Ninth Circuit affirmed the district court's order as to liability and held that City National engaged in prohibited self-dealing under section 406(b) of ERISA by setting and approving its own fees from Plan assets for serving as its own recordkeeper. Furthermore, such conduct was not exempt under section 408(c)(2) as reasonable compensation for services provided by a fiduciary such as recordkeeping services.In regard to damages, the panel affirmed in part and reversed in part, holding that the loss associated with a prohibited transaction is at least the entire cost of the prohibited transaction. In cases where the fiduciary has engaged in self-dealing, the panel has previously held that the "entire cost" of the transaction is the total amount of the illegal compensation that the fiduciary paid itself. Therefore, the district court correctly determined that the expenses were City National's burden to prove and any doubts related to damages should be resolved in the DOL's favor. In this case, no reasonable jury could find in favor of City National given the paucity of the evidence demonstrating that the additional offsets represent expenses actually incurred by CNB in servicing the Plan. View "Acosta v. City National Corporation" on Justia Law

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Three small employers in Montana filed suit against health insurance companies, alleging claims under the Employee Retirement Income Security Act of 1974 (ERISA), as well as state law claims based on defendants' representations. The Ninth Circuit affirmed the district court's dismissal of plaintiffs' ERISA claims and held that plaintiffs failed to state a claim for breach of fiduciary duty under 29 U.S.C. 1132(a)(2) where defendants did not exercise control over plan assets when charging or spending the allegedly excessive premiums.However, the panel reversed the district court's dismissal of plaintiffs' state law claims and held that ERISA did not expressly preempt state-law claims against an insurer that did not bear on an ERISA-regulated relationship. Furthermore, the state law claims were not barred by conflict preemption. The panel reversed the district court's dismissal with prejudice of the state-law claims so that plaintiffs may amend their complaint to state the fraud allegations with greater particularity. View "The Depot, Inc. v. Caring for Mountanans, Inc." on Justia Law