Justia ERISA Opinion Summaries

by
The owner and CEO of Southern Pines (Pat) recruited Kairys as Vice President of Sales to grow the company’s cryogenic trucking services. Soon after he started the job, Kairys required hip replacement surgery. Kairys had surgery and missed seven days of work. Southern was self-insured. Kairys’s surgery caused its health insurance costs to rise markedly. According to Kairys, after he returned to work, Pat’s brother (the VP) told him to “lay low” because Pat was upset. Four months later, Pat fired Kairys, claiming that Southern had “maxed out” its sales potential in cryogenic trucking. Weeks later, Souther hired a part-time worker in a hybrid role that included work that had been done by Kairys.Kairys sued, alleging discrimination and retaliation, citing the Americans with Disabilities Act, the Age Discrimination in Employment Act, the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001, and state laws. A jury rejected Kairys’s ADA and ADEA claims and returned an advisory verdict for Southern on the ERISA claim.The district court independently considered the ERISA claim and found that Kairys had proved retaliation for using ERISA-protected benefits and interfered with his right to future benefits. The court awarded Kairys $67,500 in front pay and $111, 981.79 in attorney fees. The Third Circuit affirmed. The judgment for Kairys on the ERISA claim was not inconsistent with the jury’s verdict on the other claims and was supported by sufficient evidence. View "Kairys v. Southern Pines Trucking, Inc" on Justia Law

by
Plaintiff sued Reliance Standard Life Insurance Company under 29 U.S.C. Section 1132(a)(1)(B), seeking to recover long-term disability benefits. The district court granted Plaintiff’s motion for summary judgment and denied Reliance’s cross-motion. Reliance appealed, and the Eighth Circuit reversed.   The court explained that the cases cited do not demonstrate that Reliance has a history of biased claims administration. Nor do they show some other systemic flaw in its claims review process that affected Reliance’s review of Plaintiff’s claim. On the other hand, Reliance does not argue that it maintained structural separations to minimize its conflict of interest. Therefore, the conflict of interest, in this case, deserves “some weight,” but the court concluded that it does not indicate that Reliance abused its discretion. The court wrote that substantial evidence supports Reliance’s decision, and neither the decisional delay in this case nor the purported conflict of interest leads us to conclude that Reliance abused its discretion. View "Melissa McIntyre v. Reliance Standard Life" on Justia Law

by
On behalf of a class, Plaintiff sued Aon Hewitt Investment Consulting for investment advice given to Lowe’s Home Improvement to help manage its employees’ retirement plans. Aon, first as an investment consultant and later as a delegated fiduciary, owed the plan fiduciary duties under the Employee Retirement Income Security Act. Plaintiff claimed that Aon’s conduct violated the core duties of loyalty and prudence. After a five-day bench trial, the district court held that Aon, in fact, did not breach its fiduciary duties. Plaintiff appealed.   The Fourth Circuit affirmed. The court explained that the district court that Aon’s recommendation was not motivated by self-interest. And Plaintiff’s contention that Aon’s research conducted before it was Lowe’s delegated fiduciary could not discharge its duty of prudence also falls short. Aon engaged in a reasoned decision-making process by reviewing comparable funds. It makes no difference here that the review occurred when it established the fund (which was before Aon became Lowe’s delegated fiduciary). Plus, it continued to monitor the fund. So Aon did not violate the duty of prudence. View "Benjamin Reetz v. Aon Hewitt Investment Consulting, Inc." on Justia Law

by
Berkelhammer and Ruiz participated in the ADP TotalSource Retirement Savings Plan, an investment portfolio managed by NFP. They filed suit under section 502(a)(2) of the Employment Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1132, for their own losses and derivatively on behalf of the Plan. The Plan’s contract with NFP contained an agreement to arbitrate disputes between the two entities. Berkelhammer and Ruiz argued that since they did not personally agree to arbitrate, the arbitration provision did not reach their claims. The district court disagreed, holding that Berkelhammer and Ruiz stand in the Plan’s contractual shoes and must accept the terms of the Plan’s contract.The Third Circuit affirmed. Civil actions under section 502(a)(2) “for breach of fiduciary duty [are] brought in a representative capacity on behalf of the plan as a whole” to “protect contractually defined benefits.” Because the plaintiffs’ claims belong to the Plan, the Plan’s consent to arbitrate controls. The presence or absence of the individual claimants’ consent to arbitration is irrelevant. View "Berkelhammer v. ADP TotalSource Group Inc." on Justia Law

by
Eligibility for disability payments from the Fund turns on how many credits an ironworker has accumulated (a credit is equal to 1,000 hours of work on union jobs in a given year); those with more than five but fewer than 15 credits are entitled to disability benefits if “totally and permanently disabled as the result of an accident sustained while on the job and employed by a Contributing Employer.” Lane, with nine credits as a union ironworker, applied for disability benefits. Lane was approved for Social Security Disability Insurance. The Fund’s Administrator requested information to connect Lane’s disability to an on-the-job injury. Lane explained that he suffered on-the-job injuries to his shoulder and knee and sent medical records, none of which connected his disability to the cited May 2014 accident. Lane admitted that his SSA award was determined by a combination of factors, not just the 2014 accident. A letter from Lane’s physician referred to several work-related injuries without identifying the work-related events or whether those injuries were the sole basis for the SSA’s disability award.After review by the Medical Review Institute of America concluded that the records did not establish that the SSA disability related to the 2014 accident, the Fund’s Trustees affirmed the denial of Lane’s Claim. The Seventh Circuit affirmed summary judgment in favor of the Fund under the Employee Retirement Income Security Act, 29 U.S.C. 1002, characterizing the denial as “not downright unreasonable.” View "Lane v. Structural Iron Workers Local No. 1 Pension Trust Fund" on Justia Law

by
Henry participated in an employee stock ownership plan (ESOP) sponsored by his employer. After the ESOP purchased stock at what Henry believed was an inflated price, Henry filed a lawsuit against the plan’s trustee and executives of his employer, alleging that the defendants breached fiduciary duties to the ESOP imposed by the Employment Retirement Income Security Act (ERISA), 29 U.S.C. 1001, and engaged in transactions prohibited by ERISA. The defendants argued that an arbitration provision, added to the ESOP’s plan documents after Henry joined the ESOP, barred Henry from pursuing his claims in federal court. The district court denied their motion to dismiss, reasoning that all parties to an arbitration agreement must manifest assent to the agreement, and Henry did not manifest his assent to the addition of an arbitration provision to the ESOP plan document.The Third Circuit affirmed, first confirming its jurisdiction. The motion to dismiss was effectively a motion to compel arbitration, 9 U.S.C. 16(a) provides appellate jurisdiction to review the denial of that motion. The class action waiver (and, by extension, the arbitration provision as a whole) is not enforceable because it requires him to waive statutory rights and remedies guaranteed by ERISA. View "Henry v. Wilmington Trust NA" on Justia Law

by
Plaintiff sued Zurich American Life Insurance Company of New York∗ (“Zurich”) in district court challenging Zurich’s denial of long-term disability (“LTD”) benefits under the Employment Retirement Income Security Act of 1974 (“ERISA”). The parties cross-moved for judgment on the record, and the district court awarded judgment to Zurich. Plaintiff appealed.   The Fourth Circuit affirmed. The court held that Zurich’s decision to deny benefits followed a principled reasoning process and was supported by substantial evidence. The court explained that Plaintiff insists that Zurich abused its discretion by failing to evaluate his particular job responsibilities in determining his disability status. The court explained that Plaintiff misunderstands what the Plan requires. The Plan defines “Regular Occupation” as “the occupation [the employee is] routinely performing when [his] disability begins.” And the Plan explains that Zurich “will look at [the employee’s] occupation as it is normally performed in the national economy, instead of how the work tasks are performed for a specific employer or at a specific location.” Of note, Zurich completed and considered a “Physical Requirements and Job Demand Analysis” that evaluated Plaintiff’s job responsibilities. That analysis concluded that his writer/editor position was a sedentary one that required minimal physical exertion. Under the Plan, it was Plaintiff’s burden, not Zurich’s, to provide “written proof of [his] claim for disability benefits.” Thus, Zurich did not abuse its discretion by not obtaining additional vocational evidence, as neither the Plan nor case law affirmatively requires it to have done so. View "Kevin Geiger v. Zurich American Insurance Company" on Justia Law

by
Plaintiff underwent bariatric surgery to lose weight. A few months later, Plaintiff began working for Zimmerman Transfer, Inc. and became a participant in its self-insured employee benefit plan. Zimmerman is the plan administrator, and Benefit Plan Administrators of Eau Claire, LLC (“BPA”) served as the third-party administrator until January 2020. After exhausting his administrative appeals, Plaintiff sued BPA and Zimmerman for benefits under Section 1132(a)(1)(B). He then moved for summary judgment against BPA and Zimmerman. Both Defendants filed cross-motions for summary judgment, which the district court granted.   The Eighth Circuit affirmed. The court explained that because Plaintiff’s plan specifically excludes coverage of treatment for complications of weight-reduction surgery, neither Iowa law nor the ACA requires that his treatment be covered. It is undisputed that Plaintiff’s treatment was due to a complication of his prior bariatric surgery. Thus, Iowa law and the ACA do not require that his treatment be covered. Further, the court wrote that imposing and enforcing coverage limitations, even if it results in a plan participant paying large medical bills, is not inconsistent with the plan’s goal because the plan must allocate limited resources among all plan participants. Accordingly, the court concluded that there was no abuse of discretion in denying Plaintiff’s claim for benefits because the interpretation of the plan was reasonable, and the decision to deny benefits was supported by substantial evidence. View "Darrin Shafer v. Zimmerman Transfer, Inc." on Justia Law

by
The Plan is an employee welfare benefit plan under the Employee Retirement Income Security Act (ERISA). W&S denied Laake’s claim for extended long-term disability (LTD) benefits, indicating that Plan limited LTD benefit to 24 months if the disabling condition is due to any mental, nervous, psychiatric condition or chronic pain.” The Plan refers to “chronic pain syndrome.” No medical doctor had ever diagnosed Laake with “Chronic Pain Syndrome.” Although the Plan fails to define “Chronic Pain Syndrome,” Schedule C—which lists conditions that are excluded from extended LTD benefits—explicitly incorporates the Diagnostic and Statistical Manual of Mental Disorders, which does not specifically include “Chronic Pain Syndrome,” but does detail the symptoms and features of “Pain Disorder.” W&S did not ask Laake’s physicians in its questionnaires about the Mental Illness exclusion or “Chronic Pain Syndrome.” None of her physicians indicated that there was any psychological basis for her pain.The district court determined that Laake was entitled to benefits, imposed penalties against W&S, and awarded Laake attorney’s fees and costs, 29 U.S.C. 1132(g)(1). The Sixth Circuit affirmed. In denying benefits without any explanation or supporting evidence, W&S acted arbitrarily and capriciously. Because W&S provided notice that implied one basis for its denial of benefits, but in its final decision included an entirely new basis, it failed to substantially comply with ERISA’s notice requirements. The court noted a finding that W&S engaged in particularly “egregious conduct throughout the course of this litigation.” View "Laake v. Western & Southern Financial Group Flexible Benefits Plan" on Justia Law

by
After gallbladder surgery, Tranbarger began suffering from multiple medical conditions, including physical pain and chronic fatigue. At work, Tranbarger continued as an accounts receivable manager, a primarily sedentary position. Her supervisor modified some of her responsibilities to accommodate her reduced capacity. Tranbarger resigned in July 2016, citing pain and fatigue.Through her employer, Tranbarger was enrolled in Lincoln's disability insurance plan. About 14 months after resigning, Tranbarger filed a claim for long-term disability benefits. Tranbarger was entitled to benefits if she could show “total disability” such that she was “unable to perform each of the [m]ain [d]uties” of an accounts receivable manager during a six-month “Elimination Period” following her resignation. Tranbarger presented a Social Security ruling in her favor, doctors’ notes, and statements from individuals otherwise familiar with her condition. Lincoln denied Tranbarger’s claim. She sued under the Employee Retirement Income Security Act (ERISA).The Sixth Circuit affirmed a judgment in favor of Lincoln. Tranbarger did not demonstrate a continuous inability to perform the main duties of an accounts receivable manager during the six months following her resignation. Although she provided diagnoses from the Mayo Clinic and established that she suffered pain and fatigue, there was little evidence about whether Tranbarger could perform her job functions. View "Tranbarger v. Lincoln Life & Annuity Co. of New York" on Justia Law