Justia ERISA Opinion Summaries
SCOTT WOLF V. INS. CO. OF N. AMERICA
Plaintiff's son died in a single-vehicle collision. At the time, he was intoxicated and driving the wrong way on a one-way road. The accidental death and dismemberment insurance policy obtained from defendant Life Insurance Company of North America (LINA) by the plaintiff via his employer paid benefits for a “Covered Accident,” defined as “[a] sudden, unforeseeable, external event that results, directly and independently of all other causes.”Applying the Padfield test, Padfield v. AIG Life Ins. Co., 290 F.3d 1121 (9th Cir. 2002), the son’s death was an “accident” because, while the facts demonstrated that the son engaged in reckless conduct, the record did not show that his death was “substantially certain” to result from that conduct. Thus, the Ninth Circuit affirmed the district court's finding. View "SCOTT WOLF V. INS. CO. OF N. AMERICA" on Justia Law
New York State Nurses Association Benefits Fund v. The Nyack Hospital
The case concerned the scope of the audit authority of a multi-employer employee benefit fund covered by the Employee Retirement Income Security Act (“ERISA”). The New York State Nurses Association Benefit Fund (the “Fund”) sought an audit of the Nyack Hospital’s (the “Hospital’s”) payroll and wage records. The Hospital objected, claiming that the Fund had the authority to inspect only the payroll records of employees the Hospital identified as members of the collective bargaining unit. The district court held that the Fund was entitled to the records of all persons the Hospital identified as registered nurses but not to the records of any other employees. The Second Circuit reversed in part and affirmed in part. The court reversed to the extent the district court granted the Hospital’s cross-motion for summary judgment and denied the Fund’s motion for summary judgment. To the extent the district court granted the Fund’s motion for summary judgment and denied the Hospital’s cross-motion for summary judgment, the court affirmed. The court held that the audit sought by the Fund was authorized by the Trust Agreement and that the Hospital did not present evidence that the audit constituted a breach of the Fund’s fiduciary duty under ERISA. Accordingly, the audit was within the scope of the Fund trustees’ authority under the Supreme Court’s decision in Central States, Southeast and Southwest Areas Pension Fund v. Central Transport, Inc., 472 U.S. 559 (1985). View "New York State Nurses Association Benefits Fund v. The Nyack Hospital" on Justia Law
Dean v. National Production Workers Union, Local 707
The NPWU previously represented the plaintiffs, Parsec employees, participating in the NPWU’s retirement multiemployer defined-contribution plans. A lawsuit brought by the Department of Labor settled, requiring the Severance Plan to pay back loans and approving the Plan’s administrators and its third-party accounting firm, Krol. Parsec employees later voted to decertify the NPWU and elect the Teamsters as their new bargaining representative. The Teamsters told Parsec employees that their retirement accounts would roll over to the Teamsters’ plan. NPWU stated that the retirement accounts would become inactive but remain under NPWU control. After the election, Parsec stopped contributing to the NPWU plan and began contributing to the Teamsters’ plan. Parsec employees’ accounts became inactive but remained under NPWU control. Plaintiffs alleged excessive expenses, undisclosed payments to NPWU officers and their relatives, and high salaries. Plaintiffs requested copies of documents, to which they were entitled under the Employee Retirement Income Security Act (ERISA). The Plans responded but did not provide certain documents, including a “summary plan description” for the 401(k) Plan, which did not exist. Plaintiffs sent several letters requesting that the Plans roll over their accounts to the Teamsters’ plan. The Plans refused.Plaintiffs filed a putative class action. The Seventh Circuit affirmed the dismissal of the suit. The Plans terms did not require rollover and the allegations failed to show that the trustees breached their fiduciary duties. View "Dean v. National Production Workers Union, Local 707" on Justia Law
Walsh v. Alight Solutions, LLC
Alight provides recordkeeping services for employee healthcare and retirement benefit plans, some of which are governed by ERISA, 29 U.S.C. 1001–1461 The Department of Labor investigated Alight, following a discovery that Alight processed unauthorized distributions of plan benefits due to cybersecurity breaches, and sent Alight an administrative subpoena duces tecum, seeking documents in response to 32 inquiries, including broad demands, such as “[a]ll documents and communications relating to services offered to ERISA plan clients.” Alight produced some documents but objected to several inquiries, citing its duty to keep certain information confidential. The Department petitioned for enforcement of the subpoena. Alight produced additional materials but redacted most of the documents to remove client identifying information, preventing the Department from discerning potential ERISA violations. Alight asked the court to quash or limit the subpoena and permit redactions. Alight’s legal consultant projected full compliance would require “thousands of hours of work.” The Department clarified or narrowed its requests.The Seventh Circuit affirmed an order granting the Department’s petition to enforce the subpoena with some modifications. The court rejected Alight’s arguments that the subpoena is unenforceable because the Department lacks authority to investigate the company because it is not a fiduciary under ERISA, or cybersecurity incidents generally; that the subpoena’s demands are too indefinite and unduly burdensome, and that the district court abused its discretion by denying Alight’s request for a protective order to limit production of certain sensitive information. View "Walsh v. Alight Solutions, LLC" on Justia Law
Florence Lake Investments v. Berg
The Supreme Court held that the Employee Retirement Income Security Act of 1974 (ERISA), 19 U.S.C. 1001 et seq., and in particular, ERISA's anti-alienation statute, shields a 401K plan administrator from state garnishment liability.Florence Lake Investments, LLC obtained a judgment against Jason Berg and his wife, Mary Berg, and made several collection efforts through postjudgment proceedings for garnishment or execution. Florence served garnishment interrogatories on Zoetis, Inc., as administrator of Berg's 401K account, but Zoetis did not disclose its role regarding Berg's 401K account. Florence then filed an application to determine garnishee liability against Zoetis. The court overruled the application, concluding that Zoetis was not liable for failing strictly to comply with the garnishment statutes by not disclosing Berg's 401K because ERISA governed the account, and therefore, the account could not be subject to garnishment. The Supreme Court affirmed, holding (1) ERISA's anti-alienation statute prevented Florence from acquiring Berg's right to the funds in his 401K account; and (2) therefore, Zoetis could not be held liable for failing to comply with the garnishment statutes. View "Florence Lake Investments v. Berg" on Justia Law
Operating Engineers’ Local 324 Fringe Benefits Funds v. Rieth-Riley Construction Co.
The Sixth Circuit reversed the judgment of the district court dismissing this ERISA action for lack of jurisdiction on the grounds that no contract bound the parties, holding that the presence of a live contract goes to the merits of this action, not the district court's jurisdiction to hear it.A group of employee benefits funds sued Defendant in a federal district court alleging breach of contract for late contributions under the Employee Retirement Income Security Act (ERISA). Defendant responded that no contract existed and that the presence of a live contract was a jurisdictional prerequisite to Plaintiffs' ERISA suit, meaning that the claim should have been brought under the National Labor Relations Act and that the National Labor Relations Board had exclusive jurisdiction to hear Plaintiffs' grievances. The district court dismissed the suit without prejudice, holding that it lacked jurisdiction to hear Plaintiffs' claim. The Sixth Circuit reversed, holding that the presence of a live contract is not an essential jurisdictional fact in an action brought under section 515 of ERISA. Rather, the presence of a live contract goes to the merits of Plaintiffs' ERISA claim. View "Operating Engineers' Local 324 Fringe Benefits Funds v. Rieth-Riley Construction Co." on Justia Law
Burke v. Boeing Co.
In this putative class action filed shortly after two fatal crashes of new Boeing 737 MAX airliners led to a worldwide grounding of those planes and a halt to production, resulting to a significant drop in the value of Boeing stock, the Seventh Circuit affirmed the judgment of the district court granting Defendants' motion to dismiss under Fed. R. Civ. P. 12(b)(6), holding that there was no error.At issue was The Boeing Company's employee stock ownership plan (ESOP) and whether Boeing plan fiduciaries' delegation to an independent outside fiduciary the selection and management of investment options for the ESOP protected the company and company insiders from liability for the plan's continued offering of Boeing stock as an independent option for employees before and during the time when the Boeing stock dropped. Plaintiffs argued that Boeing's continuous concealment of material facts relating to the 737 MAX jets caused the price of the stock to be artificially inflated and that Defendants should disclosed the safety issues to the public immediately. The district court dismissed the action. The Seventh District affirmed, holding that the delegation of investment decisions to an independent fiduciary meant that Boeing did not act in an ERISA fiduciary capacity in connection with the continued investments in Boeing stock. View "Burke v. Boeing Co." on Justia Law
Virgil Harris v. The Lincoln National Life Insurance Company, et al
Under the Employment Retirement Income Security Act, 29 U.S.C. Section 1132(a)(1)(B), a plan administrator’s benefits decision is subject to plenary review in federal court unless the administrator is given discretion to determine eligibility or construe the terms of the plan. If the administrator has discretion, a court determines whether its benefits decision was arbitrary and capricious (i.e., whether it lacked a reasonable basis). In this ERISA case, all parties agree that Lincoln’s denial of long-term disability benefits to Plaintiff triggered de novo review because the plan did not give Lincoln discretion. The district court, acknowledging that its review of the denial was plenary, ruled that Plaintiff could not submit evidence that had not been presented to Lincoln before it denied benefits. The Eleventh Circuit reversed holding that the district court’s evidentiary ruling constituted error under Eleventh Circuit precedent. The court explained that Lincoln also argues that even under Moon and Kirwan an ERISA plaintiff does not have the unfettered right to introduce new evidence when challenging the denial of benefits under plenary review. However, the court explained it has never mentioned, a showing of good cause to present new evidence in ERISA benefit cases governed by the de novo standard. Further, although Lincoln that under plenary review the administrative record supports the denial of long-term disability benefits to Plaintiff, the court cannot, however, affirm on this basis. Accordingly, the district court erred by not considering Plaintiff's post-denial evidence, and Lincoln does not assert that this error was harmless. View "Virgil Harris v. The Lincoln National Life Insurance Company, et al" on Justia Law
Board of Trustees v. Four-C-Aire, Inc.
The Board of Trustees of the Sheet Metal Workers’ National Pension Fund (“the Fund”) sought to recover a delinquent exit contribution from Four-C-Aire, Inc., a former participating employer, under Section 515 of the Employee Retirement Income Security Act of 1974 (“ERISA”). 29 U.S.C. Section 1145. The Fund claims Four-C-Aire’s obligation arose under a collective-bargaining agreement (“the CBA”) between the Sheet Metal Workers’ International Association Local Union No. 58 and the Central New York Sheet Metal Contractors Association, a multiemployer bargaining unit. According to the Fund, Four C-Aire signed on to this preexisting agreement while it was a member of the Contractors Association. The Fourth Circuit affirmed, finding that Four-C-Aire adopted the agreement by its conduct. The court held that even if Four-C-Aire had preserved the issue, it’s meritless. The record contains several iterations of the written trust documents, including those imposing the exit-contribution requirement. And the Fund’s Director of Operations verified each version of the document in a declaration to the district court. Further, the court wrote there is no evidence the trust documents are invalid. In sum, Four-C-Aire offers no reason why the court shouldn’t enforce the plain terms of the agreement and trust documents, as ERISA requires. View "Board of Trustees v. Four-C-Aire, Inc." on Justia Law
Ministeri v. Reliance Standard Life Insurance Co.
The First Circuit affirmed the judgment of the district court in favor of an employee's widow in this insurance dispute, holding that the employee did not lose life insurance coverage under his employer's group policy after he developed a brain tumor that disrupted his usual work.Plaintiff, the employee's widow, submitted a statement to Insurer claiming approximately $1 under her late husband's life insurance policy. Insurer denied the claim. Plaintiff then sued, alleging wrongful denial of benefits under section 502(a) of ERISA, 29 U.S.C. 1132(a)(1)(B), (a)(3). The insurance company denied life insurance coverage on the grounds that the employee's coverage under the policy had lapsed. The district court granted summary judgment for Plaintiff. The First Circuit affirmed, holding (1) because the policy language invoked by Insurer in this case was less than clear the rule that ambiguous terms in an insurance policy should be read in favor of coverage applied; and (2) the employee was covered at the time of his demise. View "Ministeri v. Reliance Standard Life Insurance Co." on Justia Law