Justia ERISA Opinion Summaries

The Second Circuit affirmed the district court's award of equitable relief in this Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., action. The court rejected defendants' challenges to the district court's award of equitable relief under section 502(a)(3). The court held that the district court did not err in rejecting defendants' challenge to the timeliness of participants' claims; ordering class-wide relief on participants' section 404(a) claims without requiring individualized proof of detrimental reliance; and concluding that mistake, a prerequisite to the equitable remedy of reformation, had been shown by clear and convincing evidence as to all class members. Finally, the district court did not abuse its discretion by awarding equitable relief. View "Osberg v. Foot Locker, Inc." on Justia Law

The Eighth Circuit affirmed MetLife's denial of long term disability (LTD) benefits to plaintiff under a group insurance plan sponsored by her former employer pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that plaintiff presented no evidence of factors tending to demonstrate a consequential conflict of interest, or other indicia of biased decision making; the district court did not err by using an abuse of discretion standard of review; and MetLife did not abuse its discretion by denying LTD benefits to plaintiff where it properly considered all medical records, APS reports, comments, and other information submitted by plaintiff and her physicians. View "Cooper v. Metropolitan Life Insurance Co." on Justia Law

Reliance challenged the district court's award of disability benefits to plaintiff under a plan pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., and the amount of benefits owed. The DC Circuit affirmed, holding that plaintiff proved partial disability. In this case, the conflict of interest factor in the standard of review, as well as plaintiff's medical record, lack of full time work, and release to return to work only "as tolerated" convinced the court that she established partial disability. The court explained that, according to the express terms of the Plan, partial disability was equivalent to total disability within the relevant period. View "Marcin v. Reliance Standard Life Insurance Co." on Justia Law

Plaintiff filed suit under section 502(a)(1)(B) of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)(B), after the plan administrator determined that plaintiff's disability-onset date rendered him ineligible for benefits. The Fourth Circuit affirmed the district court's conclusion that plaintiff was entitled to benefits and order requiring the Plan to provide the benefits. The court explained that the Board failed to follow a reasoned process or explain the basis of its determination -- neither addressing nor even acknowledging new and uncontradicted evidence supporting plaintiff's application, including that of the Plan's own expert. View "Solomon v. Bert Bell/Pete Rozelle NFL Player Retirement Plan" on Justia Law

Plaintiff-appellee Elizabeth Cates filed on her behalf and a putative class asserting claims against the defendant-appellee INTEGRIS Health, Inc. for breach of contract, violation of the Oklahoma Consumer Protection Act, deceit, specific performance, and punitive damages. INTEGRIS successfully moved to dismiss the claims based on the ground that they are all preempted by the Employee Retirement Income Security Act. Cates appealed. Because the trial court in this matter did not take into consideration the federal Tenth Circuit Court of Appeals’ decision in Salzer v. SSM Health Care of Oklahoma Inc., 762 F.3d 1130 (10th Cir. 2014), which was factually similar to the facts of this case and found that the plaintiff’s claims were not preempted, the Oklahoma Supreme Court reversed and remanded the trial court in this matter for reconsideration in light of Salzer. View "Cates v. Integris Health, Inc." on Justia Law

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

Former employees of World Airways challenged the dismissal of their complaint seeking damages for fraud, breach of contract and violation of an employee benefit plan. The Second Circuit agreed with the district court that plaintiffs' state law claims arose under the Railway Labor Act (RLA), 45 U.S.C. 151 et seq., and were thus preempted. Because those claims bear a close resemblance to claims brought pursuant to the Employee Retirement Income Securities Act (ERISA), 29 U.S.C. 1001 et seq., the court found it appropriate to borrow and apply the three‐year statute of limitations set forth in Section 1113 of ERISA rather than the six‐month limitations period the district court borrowed from Section 10(b) of the National Labor Relations Act (NLRA), 29 U.S.C.160(b). Accordingly, the court vacated the dismissal of the RLA claims and remanded for further consideration. The court affirmed in all other respects. View "Pruter v. Local 210’s Pension Trust Fund" on Justia Law

The Pioneer Centres Holding Company Employee Stock Ownership Plan and Trust and its trustees sued Alerus Financial, N.A. for breach of fiduciary duty in connection with the failure of a proposed employee stock purchase. The district court granted summary judgment to Alerus after determining the evidence of causation did not rise above speculation. The Plan appealed, claiming the district court erred in placing the burden to prove causation on the Plan rather than shifting the burden to Alerus to disprove causation once the Plan made out its prima facie case. In the alternative, the Plan argued that even if the district court correctly assigned the burden of proof, the Plan established, or at the very least raised a genuine issue of material fact regarding, causation. Finding no reversible error, the Tenth Circuit affirmed the district court. View "Pioneer Centres Holding Co v. Alerus Financial, N.A." on Justia Law

The Employee Retirement Income Security Act (ERISA) obligates private employers offering pension plans to adhere to rules designed to ensure plan solvency and protect plan participants, 29 U.S.C. 1003(b)(2). ERISA exempts “A plan established and maintained for its employees . . . by a church . . . [which] includes a plan maintained by an organization . . . the principal purpose . . . of which is the administration or funding of [such] plan . . . for the employees of a church . . . , if such organization is controlled by or associated with a church,” section 1002(33)(C)(i). Defendants, church-affiliated nonprofits that run hospitals, offer their employees defined-benefit pension plans, which were established by the hospitals themselves, and are managed by internal employee-benefits committees. Current and former employees filed class actions alleging that the hospitals’ plans did not fall within ERISA’s "church plan" exemption because they were not established by a church. The lower courts agreed with the employees. The Supreme Court reversed. A plan maintained by a principal-purpose organization qualifies as a “church plan,” regardless of who established it. In amending ERISA, Congress deemed the category of plans “established and maintained by a church” to “include” plans “maintained by” principal-purpose organizations. View "Advocate Health Care Network v. Stapleton" on Justia Law

3M filed an insurance claim to recover losses incurred on a number of investments due to fraud perpetrated by its own investment advisors. The Eighth Circuit affirmed the district court's grant of summary judgment to the Insurers, holding that the ownership requirement of Endorsement 8 applies to the Employee Dishonesty provision. Therefore, 3M does not own the stolen earnings and cannot seek coverage for the earnings under the Policy. Until the earnings were distributed to the partners, the stolen earnings were property of WG Trading, not 3M. The court explained that it is fundamental that property acquired with partnership funds is partnership property, and individual partners do not own partnership assets until the winding up of the partnership. Finally, the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., does not alter general commercial property rights, but merely defines the nature and scope of the fiduciary duties owed to plan participants. View "3M v. National Union Fire Insurance" on Justia Law