Justia ERISA Opinion SummariesArticles Posted in US Court of Appeals for the Sixth Circuit
Cooper v. Honeywell International, Inc.
The plaintiffs, former employees at Honeywell’s Boyne City, Michigan auto parts plant, were represented by the UAW while working. The collective bargaining agreement (CBA) between that union and Honeywell that became effective in 2011 and expired in 2016 stated: Retirees under age 65 who are covered under the BC/BS Preferred Medical Plan will continue to be covered under the Plan, until age 65, by payment of 16% of the retiree monthly premium costs ... as adjusted year to year,” Article 19.7.4. The plaintiffs took early retirement under the 2011 CBA and received Honeywell-sponsored healthcare, consistent with Article 19.7.4. Other Boyne City employees had retired before the 2011 CBA took effect, but were still eligible for benefits under Article 19.7.4. In 2015, Honeywell notified the UAW and the Boyne City retirees that it planned to terminate retiree medical benefits upon the 2011 CBA’s expiration. The plaintiffs, citing the Labor Management Relations Act, the Employment Retirement Income Security Act, and Michigan common law estoppel, obtained a preliminary injunction. The Sixth Circuit reversed, reasoning that the CBA did not clearly provide an alternative end date to the CBA’s general durational clause, so the plaintiffs have not shown a likelihood of success on the merits. View "Cooper v. Honeywell International, Inc." on Justia Law
Allied Construction Industries v. City of Cincinnati
Cincinnati ordinances provide guidelines for selecting the “lowest and best bidder” on Department of Sewers projects to “ensure efficient use of taxpayer dollars, minimize waste, and promote worker safety and fair treatment of workers” and for bids for “Greater Cincinnati Water Works and the stormwater management utility division,” to employ skilled contractors, committed to the city’s “safety, quality, time, and budgetary concerns.” Allied alleged that the Employee Retirement Income Security Act (ERISA) preempted: a requirement that the bidder certify whether it contributes to a health care plan for employees working on the project as part of the employee’s regular compensation; a requirement that the bidder similarly certify whether it contributes to an employee pension or retirement program; and imposition of an apprenticeship standard. Allied asserts that the only apprenticeship program that meets that requirement is the Union’s apprenticeship program, which is not available to non-Union contractors. The ordinances also require the winning contractor to pay $.10 per hour per worker into a city-managed pre-apprenticeship training fund, not to be taken from fringe benefits. The district court granted Allied summary judgment. The Sixth Circuit reversed. Where a state or municipality acts as a proprietor rather than a regulator, it is not subject to ERISA preemption. The city was a market participant here: the benefit-certification requirements and the apprenticeship requirements reflect its interests in the efficient procurement of goods and services. View "Allied Construction Industries v. City of Cincinnati" on Justia Law
Sun Life Assurance Co. v. Jackson
Bruce and Bridget married in 1993. Their only child, Sierra, was born in 1995. In 2003, Bruce signed up for a life insurance plan sponsored by his employer and governed by the Employee Retirement Income Security Act (ERISA). Bruce listed his uncle as the sole beneficiary. Bruce and Bridget divorced in 2006. Bruce died in 2013, insured for $48,000 in basic life insurance and $191,000 in optional life insurance. In their 2006 divorce decree, Bruce and Bridget agreed to maintain any employer-related life insurance policies for the benefit of Sierra until she turned 18 or graduated from high school. Bruce had not changed his beneficiary. The district court ordered payment to Sierra. The Sixth Circuit affirmed. The divorce decree suffices as a qualified domestic relations order that, incorporating the Jacksons’ separation agreement and their shared parenting plan, “clearly specifies” Sierra as the beneficiary under 29 U.S.C. 1056(d)(3)(C). Her parents’ (alleged) non-compliance with the decree does not limit Sierra’s rights under ERISA. View "Sun Life Assurance Co. v. Jackson" on Justia Law
Stevens Engineers & Constructors, Inc. v. Local 17 Iron Workers Pension Fund
Under the Multiemployer Pension Plan Amendments Act, part of ERISA, a construction industry employer who withdraws from a multiemployer pension plan owes liability to that plan if the employer conducts work “in the jurisdiction of the collective bargaining agreement (CBA) of the type for which contributions were previously required,” 29 U.S.C. 1383(b)(2)(B)(i). The Iron Workers Local 17 Pension Fund assessed pension liability against Stevens Engineers claiming that Stevens’s activities on a certain construction project involved such work within the jurisdiction of their previous CBA. An arbitrator, the district court, and the Sixth Circuit found that Stevens did not owe pension liability to the Fund because the work identified by Local 17 did not fall within the jurisdiction of the relevant CBA, and did not otherwise require contributions by Stevens. The CBA instead allowed Stevens to assign jobs like the ones at issue to other trade unions, and a job did not trigger pension liability to the Fund if, as here, it was properly assigned to a different union. View "Stevens Engineers & Constructors, Inc. v. Local 17 Iron Workers Pension Fund" on Justia Law
Corey v. Sedgwick Claims Management Services, Inc.
Corey worked as a machine operator in Eaton’s Ohio factory. Corey has long suffered from cluster headaches— extremely painful attacks that strike several times per day for weeks on end. In 2014, Corey applied for short-term disability benefits under Eaton’s disability plan after a bout of headaches forced him to miss work. After granting a period of disability, the third party administering Eaton’s disability plan discontinued benefits because Corey failed to provide objective findings of disability. Under the plan, “[o]bjective findings include . . . [m]edications and/or treatment plan.” Corey’s physicians treated his headaches by prescribing prednisone, injecting Imitrex (a headache medication), administering oxygen therapy, and performing an occipital nerve block. The district court upheld the denial. The Sixth Circuit reversed, citing the Employee Retirement Income Security Act, 29 U.S.C. 1132(a)(1)(B). Corey’s medication and treatment plan satisfy the plan’s objective findings requirement. View "Corey v. Sedgwick Claims Management Services, Inc." on Justia Law