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

Jacob Plassmeyer incurred medical expenses during a collegiate baseball practice, and his college provided its student athletes insurance with FA. Jacob's father was also insured by the Dakotas, an employee welfare benefit plan, and Jacob was covered under this Employee Retirement Income Security Act (ERISA) plan as a dependent of his father. In this case, the trustees of Dakotas brought this declaratory judgment action against FA under section 502(a)(3) of ERISA, 29 U.S.C. 1132(a)(3), seeking an order enforcing the coordination of benefits (COB) provisions in the Dakotas plan by declaring that FA's policy provided primary coverage of Jacob's claim for medical expenses already incurred. The district court denied FA's motion to dismiss and granted Dakotas' motion for summary judgment. The Eighth Circuit held that a declaratory judgment action to enforce the Dakotas plan as it applied to the claim for benefits was both consistent with the plain language of section 502(a)(3), as construed in light of historical equitable remedies available to trustees; the court agreed with the district court that FA's coverage was primary; but the district court abused its discretion in awarding attorney fees. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Dakotas and Western Minnesota Electrical Industry Health & Welfare Fund v. First Agency, Inc." on Justia Law

The district court erred in refusing to vacate its dismissal of a pension fund’s lawsuit against an employer’s alleged alter egos. In the lawsuit, the fund sought $1.2 million in unpaid withdrawal liability that was previously assessed against the employer in a default judgment. The district court dismissed the case, concluding that subject matter jurisdiction did not exist under the Employee Retirement Income Security Act (ERISA). The court subsequently denied Appellant’s motion for post-judgment relief. The First Circuit vacated the court’s post-judgment ruling and remanded the case for further proceedings, holding that the fund’s alter ego claims were anchored in ERISA, and thus the fund had established federal subject matter jurisdiction. View "Groden v. N&D Transportation Co., Inc." on Justia Law

The Ninth Circuit vacated the district court's grant of summary judgment in favor of plaintiffs in an Employee Retirement Income Security Act (ERISA) action. The panel held that the plan comprised of two documents: the Trust Agreement and the Summary Plan Description (SPD). The Supreme Court's decision in CIGNA Corp. v. Amara, 563 U.S. 421 (2011), was not to the contrary. An SPD may constitute a formal plan document, consistent with Amara, so long as the SPD neither adds to nor contradicts the terms of existing plan documents. In this case, the SPD was a part of the plan itself, and there was no conflict between the SPD and the Trust Agreement. Therefore, Amara did not prohibit this type of arrangement, and the district court erred in concluding that the SPD was not part of the plan. The panel remanded for further proceedings. View "Mull v. Motion Picture Industry Health Plan" on Justia Law

This appeal concerned objections to the settlement of class actions that arose in the wake of a financial crisis involving SRHS and its benefits pension fund. The Fifth Circuit held that the terms of the Settlement Agreement as they affect Plan participants should have been more thoroughly examined prior to the district court's approval; the district court improperly limited its consideration to the hospital's ability to pay while ignoring a transparent explanation of the settlement's consequences for the class members; and thus the court vacated and remanded for further consideration of the enumerated issues. View "Jones v. Singing River Health Services Foundation" on Justia Law

Plaintiff filed a putative class action alleging that the Trustees breached the Pension Plan's terms, violated the Employee Retirement Income Security Act's (ERISA) sections 204 and 305, and breached their fiduciary duties by withholding $1.00 per hour from his employer contributions without providing an accrued benefit. The Ninth Circuit held that only amendment 14 was fully litigated; the district court correctly interpreted the interaction between Amendment 15, Article 5 of the Pension Plan, and the Reciprocal Agreement; ERISA section 305(e) does not apply before critical status certification; and because the panel held that the parties did not fully litigate withholdings under Amendment 24, it need not address whether the district court erred by failing to make specific findings about the alternative schedules in the Rehabilitation Plan. Accordingly, the panel affirmed in part, reversed in part, and remanded for further proceedings on the withholdings under Amendment 24. The panel vacated the award of attorneys' fees. View "Lehman v. Nelson" on Justia Law

St. Peter’s, a non-profit healthcare entity, runs a hospital. It is not a church, but has ties to a New Jersey Roman Catholic Diocese. The Bishop appoints most members of its Board of Governors and retains veto authority over Board actions. The hospital has daily Mass and Catholic devotional pictures and statues throughout the building. In 1974, St. Peter’s established a non-contributory defined benefit retirement plan; operated the plan subject to the Employee Retirement Income Security Act (ERISA); and represented that it was complying with ERISA. In 2006 St. Peter’s filed an IRS application, seeking a church plan exemption from ERISA, 26 U.S.C. 414(e); 29 U.S.C. 1002(33). In 2013, Kaplan, who worked for St. Peter’s until 1999, filed a putative class action alleging that St. Peter’s did not provide ERISA-compliant summary plan descriptions or pension benefits statements, and that, as of 2011, the plan was underfunded by more than $70 million. While the lawsuit was pending, St. Peter’s received an IRS private letter ruling. affirming the plan’s status as an exempt church plan for tax purposes. The Third Circuit initially affirmed denial of a motion to dismiss, concluding that St. Peter’s could not establish an exempt church plan because it is not a church. Following consideration by the U.S. Supreme Court in 2017, the Third Circuit vacated and reversed. View "Kaplan v. Saint Peter's Healthcare System" on Justia Law

Plaintiffs, retired officers of Booz Allen, filed suit alleging that they were improperly denied compensation when, after their retirement, Booz Allen sold one of its divisions in the Carlyle Transaction. The Second Circuit affirmed the district court's dismissal of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., claims on the ground that Booz Allen's stock-distribution program was not a pension plan within the meaning of ERISA, and denial as futile leave to amend to "augment" the ERISA claims with new allegations; affirmed the dismissal of the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961 et seq., claims on the ground that they were barred by the Private Securities Litigation Reform Act of 1995 (PSLRA), 18 U.S.C. 1964(c); but vacated the district court's judgment to the extent it denied Plaintiff Kocourek leave to amend to add securities-fraud causes of action. The court remanded for the district court to consider his claims. View "Pasternack v. Shrader" on Justia Law

Plaintiff, a member of the Employees' Retirement System of the State of Hawai'i (ERS), challenged the denial of "service-connected disability retirement" benefits after she was shot while serving as a public summer school teacher. The Supreme Court of Hawai'i held that plaintiff was eligible for service-connected disability retirement under applicable law. HRS 88-79 provides that an ERS member may be retired by the ERS for service-connected disability retirement if she was permanently incapacitated for duty as the natural and proximate result of an accident occurring while in the actual performance of duty at some definite time and place. In this case, although plaintiff's summer school employment at the school was not "membership service," it was nonetheless "service," and HRS 88-779 provided for "service-connected disability retirement," not "membership service-connected disability retirement." View "Stout v. Board of Trustees of the Employees' Retirement System" on Justia Law