Justia ERISA Opinion Summaries

From 1978-1997, Mathias worked for Caterpillar in York, Pennsylvania. In 1997 he experienced serious health issues; the Social Security Administration declared him disabled. Caterpillar covered his health insurance as an employee on long-term disability, billing him for his portion of the premium. In 2012 Mathias retired retroactively, effective October 2009. Caterpillar failed to change Mathias’s status and did not realize its mistake until 2013 when it notified Mathias that he owed $9,500 in past-due premiums, the difference between the rate for a long-term disabled employee and the rate for a retired employee. When Mathias did not pay, Caterpillar terminated his benefits. Mathias sued in the Eastern District of Pennsylvania. The plan documents require suit in the Central District of Illinois, so Caterpillar moved to transfer the case under 28 U.S.C. 1404(a). Mathias argued that the forum-selection clause was invalid in light of ERISA’s venue provision, 29 U.S.C. 1132(e)(2). The district court rejected that argument, relying primarily on Sixth Circuit precedent, holding that forum-selection clauses in ERISA plans are enforceable and not inconsistent with the text of ERISA’s venue provision. The case was transferred. Mathias petitioned for mandamus relief in the Seventh Circuit, which affirmed, holding that ERISA’s venue provision does not invalidate a forum-selection clause contained in plan documents. View "Mathias v. Mihm" on Justia Law

Studer worked at Katherine Shaw Bethea Hospital, a not‐for‐profit Dixon, Illinois healthcare provider, as an occupational therapist. After she resigned, she filed a small‐claims state court complaint, alleging that the hospital violated the Illinois Wage Payment and Collection Act (IWPCA) by failing to pay her money that she had accrued under the hospital’s Paid Days Leave policy. The hospital removed the suit to federal court, claiming that Studer’s claim was preempted by the Employee Retirement Income Security Act (ERISA). The district court denied Studer’s motion to remand, holding that it had federal‐question jurisdiction because ERISA completely preempted the state‐law claim, and granted the hospital summary judgment, holding that Studer had failed to name the welfare benefit plan as a defendant, which ERISA requires in most instances. Instead of filing an amended complaint, Studer filed a Rule 59(e) motion to amend the judgment, again arguing that ERISA did not preempt her claim. The district court denied that motion. The Seventh Circuit affirmed, noting ERISA’s “expansive” preemptive power, 29 U.S.C. 1144(a). The hospital’s benefit plan was an employee welfare benefit plan under ERISA, in which Studer participated; ERISA section 502(a)(1)(B) empowered Studer to bring a federal court action “to recover benefits due.” Studer’s IWPCA claim was not “entirely independent of” ERISA. View "Studer v. Katherine Shaw Bethea Hospital" on Justia Law