Justia ERISA Opinion Summaries

Plaintiffs submitted health plan coverage requests, which United Behavioral Health (“UBH”) denied. Plaintiffs brought claims under ERISA for breach of fiduciary duty and improper denial of benefits. The parties stipulated to a sample class, from which they submitted a sample of health insurance plans. Plaintiffs alleged that the plans provided coverage for treatment consistent with generally accepted standards of case (“GASC”) or were governed by state laws specifying certain criteria for making coverage or medical necessity determinations. Plaintiffs alleged that UBH’s Level of Care Guidelines and Coverage Determination Guidelines for making these determinations were more restrictive than GASC and were also more restrictive than state-mandated criteria. The district court certified three classes, conducted a bench trial, and entered judgment in Plaintiffs’ favor. The district court issued declaratory and injunctive relief, directed the implementation of court-determined claims processing guidelines, ordered “reprocessing” of all class members’ claims in accordance with the new guidelines, and appointed a special master to oversee compliance for ten years.   The Ninth Circuit affirmed in part and reversed in part. The panel held that Plaintiffs had Article III standing to bring their breach of fiduciary duty and improper denial of benefits claims. And the district court did not err in certifying three classes to pursue the fiduciary duty claim. However, because Plaintiffs expressly declined to make any showing, or seek a determination of, their entitlement to benefits, permitting Plaintiffs to proceed with their denial of benefits claim under the guise of a “reprocessing” remedy on a class-wide basis violated the Rules Enabling Act. View "DAVID WIT, ET AL V. UNITED BEHAVIORAL HEALTH" on Justia Law

Department of Labor regulations required the administrator of an employee benefit plan to give a claimant, “upon request,” copies of “all documents, records, and other information” that the administrator considered in making an adverse benefit determination. In 2018, the regulations were amended to eliminate “upon request” and require an administrator to provide such information “sufficiently in advance” of an adverse determination “to give the claimant a reasonable opportunity to respond.”Zall, a dentist for 20 years, sought long-term disability benefits in 2013 after pain and numbness forced him to stop working. His insurer, Standard denied the claim. In 2014, after considering additional medical information and consulting an orthopedic surgeon, Standard approved Zall’s claim, including retroactive payments. Less than a year later, Standard began reviewing his case to see if his condition was subject to a 24-month benefit limit applicable to any disability “caused or contributed to by … carpal tunnel or repetitive motion syndrome” or “diseases or disorders of the cervical, thoracic, or lumbosacral back and its surrounding soft tissue.” Standard ultimately terminated Zall’s benefits.Zall filed suit under the Employee Retirement Income Security Act, 29 U.S.C. 1001, arguing that the decision was arbitrary and capricious and that Standard violated ERISA’s procedural requirements by failing to afford him “a full and fair review.” The district court granted Standard summary judgment. The Seventh Circuit reversed and remanded. The plain language shows that the amended regulation applies; Standard failed to comply. View "Zall v. Standard Insurance Co." on Justia Law

The employers agreed that for the duration of two collective bargaining agreements (CBAs), they would make pension contributions on behalf of covered employees to the Pension Fund. Both CBAs contained “evergreen clauses” that extended them a year at a time until either party provided timely written notice expressing an “intention to terminate.” Both were to expire in January 2019. After the window for timely notice of intention to terminate on that date, the employers and the union signed new CBAs requiring pension contributions to a different fund beginning in February 2019. The employers notified the Fund that they were ceasing contributions, relying on letters the union sent in November 2018.The Seventh Circuit reversed the dismissal of the Fund’s lawsuit. Those letters did not express the union’s intent to terminate the existing CBAs, so as to satisfy the evergreen clause's termination procedure. The letters did not mention termination. They noted the date that the CBAs would expire and expressed a desire to meet to negotiate new agreements; neither of these points communicated an intent to terminate the existing agreements. In the context of an evergreen clause, expiration and termination are distinct concepts. A desire to negotiate a new contract is quite consistent with a desire to leave the existing agreement in place until a new deal is reached. The old agreements renewed under the evergreen clauses; the employers remained obligated to contribute to the Fund for one more year. View "Central States Southeast & Southwest Areas Pension Fund v. Zenith Logistics, Inc." on Justia Law

Gragg worked as a driver for 31 years. For the first 26 years, he was an employee of Overnite; after UPS acquired Overnite, he was an employee of UPS. In 2008, UPS reclassified his position from nonunion to union, so that two different pension plans funded his pension. In 2010, each plan sent him information indicating that, after Gragg turned 65, each plan would reduce his monthly payment by $1754, which was the anticipated amount of his Social Security benefit. Gragg turned 65 in 2018. The following month, each plan reduced the amount of Gragg’s monthly benefit by the entire amount of his Social Security benefit—for a combined monthly reduction of $3508. Gragg’s overall monthly income declined by $1754, rather than remaining stable as promised by the letters. Gragg filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)(B).The district court held Gragg’s suit was barred by a six-year limitations period, having accrued when he received the letters. The Sixth Circuit reversed. The letters did not cause the injury upon which Gragg sued; the underpayments did. Before that injury, his claim had not accrued. An ERISA claim based on the letters alone would have rested upon “contingent future events that may not occur as anticipated, or indeed may not occur at all.” View "Gragg v. UPS Pension Plan" on Justia Law

Reliance Standard Life Insurance Company denied Plaintiff’s claim for long-term disability benefits after concluding that she was not “Totally Disabled” as defined by her disability insurance plan. Plaintiff brought an under the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. Section 1132(a)(1)(B), arguing that the denial of benefits violated that Act. After conducting a bench trial under Federal Rule of Civil Procedure 52, the district court awarded judgment to Plaintiff. Reliance appealed, arguing that courts in the Fourth Circuit are required to resolve ERISA denial-of-benefits cases via summary judgment and that the district court erred in dispensing with this case through a bench trial. Reliance also argued that this Court must review the district court’s legal conclusions.   The Fourth Circuit affirmed. The court first held that because the plan at issue here did not require objective proof of disability, the court rejected Reliance’s contention that Plaintiff’s claim fails for the lack of such evidence. Further, the court wrote that the record supports the district court’s determination that Plaintiff’s disability was not limited to a “specific locale.” Accordingly, the court agreed that Plaintiff was “totally disabled” under the terms of the plan. View "Anita Tekmen v. Reliance Standard Life Ins." on Justia Law

A collective bargaining agreement (“CBA”) required RoadSafe Traffic Systems, Inc. to contribute to four employee benefits Funds. The Funds sued for unpaid contributions, alleging that the CBA unambiguously requires contributions for all hours worked by covered employees, regardless of the type of work performed. RoadSafe countered that the CBA unambiguously requires contributions only for construction and highway work. The district court granted summary judgment to RoadSafe. The issue on appeal was whether the CBA obligates RoadSafe to make contributions to the Funds for all or only specified types of work   The Eighth Circuit affirmed. The court explained that by its plain language, Article V of the CBA limits RoadSafe’s contribution obligations to “Building Construction” and “Highway/Heavy” categories of work. Because work coded as NON or “shop hours” is not within the definitions of either “Building Construction” or “Highway/Heavy,” the CBA does not require RoadSafe to make contributions for the coded work. Therefore, the district court properly granted summary judgment to RoadSafe. View "Cons. Laborers Welfare Fund v. RoadSafe Traffic Systems, Inc." on Justia Law

Plaintiff alleged that a participant loan program that Teachers Insurance and Annuity Association of America (TIAA) offered to her retirement plan is a prohibited transaction under the Employee Retirement Income Security Act of 1974 (ERISA). After ruling that Haley’s suit could proceed against TIAA as a nonfiduciary under ERISA, the district court certified a class of employee benefit plans whose fiduciaries contracted with TIAA to offer loans that were secured by a participant’s retirement savings. TIAA argues that the district court erred when it found that common issues predominated over individual ones without addressing the effect of ERISA’s statutory exemptions on liability classwide and without making any factual findings as to the similarities of the loans.   The Second Circuit vacated the district court’s decision holding that the predominance inquiry of Federal Rule of Civil Procedure 23(b)(3) requires that a district court analyze defenses, and the court did not do so here. Further, because the predominance inquiry of Federal Rule of Civil Procedure 23(b)(3) requires that a district court analyze defenses, and the court did not do so here, the district court did not analyze the exemptions, it also did not engage with the evidence that TIAA submitted to substantiate the purported variations among the plans. A district court cannot simply “take the plaintiff’s word that no material differences exist.” View "Haley v. TIAA" on Justia Law

Plaintiffs in these 177 consolidated appeals1 were participants in a 401(k) Profit Sharing Plan (the “Plan”) provided to employees by DST Systems, Inc. (“DST”), a financial and healthcare services company based in Kansas City, Missouri. At the time in question, DST was the Plan’s sponsor, administrator, and a designated fiduciary. Ruane Cunniff & Goldfarb Inc. (“Ruane”) was a Plan fiduciary involved in managing the Plan’s investments. Between October and December 2021, the district court issued seven largely identical orders confirming the arbitration awards to 177 claimants and granting their requests for substantial costs and attorneys’ fees. Defendants appealed, raising numerous issues.   The Eighth Circuit vacated the district court’s judgment including the awards of attorney’s fees, and the consolidated cases are remanded to the district court for determination of transfer and subject matter jurisdiction issues, to the extent necessary. The court concluded that transfer under Section 1631 is an issue that can be addressed before the district court’s subject matter jurisdiction is resolved. The court declined to consider the issue because Badgerow has changed underlying circumstances that may affect whether transfer “is in the interest of justice.” View "Theresa Hursh v. DST Systems, Inc" on Justia Law

Plaintiff challenged Lincoln’s denial of her claim for long-term disability benefits. On de novo review, the district court affirmed Lincoln’s denial of Plaintiff's claim, but it adopted new rationales that the ERISA plan administrator did not rely on during the administrative process. Specifically, the district court found for the first time that Plaintiff was not credible and that she had failed to supply objective evidence to support her claim.The Ninth Circuit held that when a district court reviews de novo a plan administrator’s denial of benefits, it examines the administrative record without deference to the administrator’s conclusions to determine whether the administrator erred in denying benefits. The district court’s task is to determine whether the plan administrator’s decision is supported by the record, not to engage in a new determination of whether the claimant is disabled. Accordingly, the district court must examine only the rationales the plan administrator relied on in denying benefits and cannot adopt new rationales that the claimant had no opportunity to respond to during the administrative process.Here, the district court erred because it relied on new rationales to affirm the denial of benefits. View "VICKI COLLIER V. LINCOLN LIFE ASSURANCE COMPANY" on Justia Law

This case presented the questions of whether and how Alaska Statute 09.55.548(b) applied when the claimant’s losses were compensated by an employer’s self-funded health benefit plan governed by the federal Employee Retirement Income Security Act (ERISA). The Alaska Supreme Court concluded that an ERISA plan did not fall within the statute’s “federal program” exception. Therefore AS 09.55.548(b) required a claimant’s damages award to be reduced by the amount of compensation received from an ERISA plan. But the Supreme Court also concluded that the distinction the statute draws between different types of medical malpractice claimants was not fairly and substantially related to the statute’s purpose of ensuring claimants do not receive a double recovery — an award of damages predicated on losses that were already compensated by a collateral source. "Because insurance contracts commonly require the insured to repay the insurer using the proceeds of any tort recovery, claimants with health insurance are scarcely more likely to receive a double recovery than other malpractice claimants. The statute therefore violates the equal protection guarantee of the Alaska Constitution." View "Knolmayer, et al. v. McCollum" on Justia Law