Justia ERISA Opinion Summaries

Plaintiff filed suit against MetLife, the administrator of a long-term disability insurance plan subject to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., seeking to recover disability benefits. The court concluded that the six-year limitations period began to run on plaintiff's ERISA claim when the cause of action accrues; plaintiff's ERISA complaint in 2012 for benefits from May 1, 1997 forward is time-barred; the court rejected plaintiff's argument that his submission of post-1997 documentation is a new claim for benefits; and MetLife did not waive any defense based on the statute of limitations by failing to specify untimeliness as a basis for denying the claim after its courtesy review. Accordingly, the court affirmed the district court's grant of summary judgment. View "Witt v. Metropolitan Life Insurance Co., et al." on Justia Law

This case arose from injuries suffered by several students during scholastic athletic activities. The students were insured by Central States, an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., employee welfare benefit plan that provides health insurance to participating Teamsters and their dependents. The students were also directly insured by separate accident policies written by Gerber. Central States subsequently filed suit against Gerber, alleging various claims for declaratory judgment and injunctive relief pursuant to federal common law and ERISA section 502(a)(3). The court held that although Central States might well be left without an appropriate remedy as a result of this decision, and that in the future its beneficiaries may be put in the unfortunate position of having to sue their insurance companies to receive benefits to which they are indisputably entitled, the claims raised by Central States are legal, not equitable, and therefore may not be brought under section 502(a)(3). Accordingly, the court affirmed the district court's grant of Gerber's motion to dismiss under Rule 12(b)(6). View "Cent. States, Se. & Sw Areas Health & Welfare Fund v. Gerber Life Ins. Co." on Justia Law

Plaintiff Sonia Graciano was injured after she was hit by a car driven by Saul Ayala. Ayala was insured by defendant California Automobile Insurance Company (CAIC). Three weeks after Graciano's attorney first contacted CAIC regarding the accident, Graciano misidentified both the driver and the applicable insurance policy. CAIC investigated the accident, identified the applicable policy and the correct driver, and offered to settle Graciano's claim with a "full policy limits offer." Graciano did not accept CAIC's full policy limits offer and, in this suit, alleged CAIC and its parent and affiliated companies acted in bad faith, based on an alleged "wrongful failure to settle." Graciano argued CAIC could have and should have earlier discovered the facts, and should have made the full policy limits offer more quickly. The jury found in favor of Graciano and this appeal followed. CAIC argued that, as a matter of law, there was no evidence to support the verdict that CAIC acted in bad faith by unreasonably failing to settle Graciano's claim against Saul. The Court of Appeal agreed, and reversed the judgment. View "Graciano v. Mercury General Corp." on Justia Law

United is the claims administrator for Plans named as defendants in this suit and all of the Plans are governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Spinedex, as assignee and would-be assignee of Plan beneficiaries, filed suit against United and the Plans seeking payment of denied benefit claims. ACS, as well as individual Plan beneficiaries, Jack Adams and Claude Aragon, joined the suit as plaintiffs. The district court granted summary judgment to defendants. The court reversed, concluding that Spinedex had Article III standing; Spinedex was not assigned the right to bring claims for breach of fiduciary duty; ACS does not have associational standing to bring suit against United; Adams' claim for breach of fiduciary duty is time-barred; Spindex's claims as assignee of beneficiaries under the Martz Agency Plan and the Acoustic Technologies Plan are not time-barred; and the anti-assignment provision of the Discount Tire Plan precluded assignment by Plan beneficiaries to Spinedex. The court vacated or reversed, and remanded for further proceedings, the district court's holdings that Aragon's claim for breach of fiduciary duty was not exhausted, that United is not a proper defendant for benefit claims under the American Express Plan, and that some of the claims assigned to Spinedex were not administratively exhausted. View "Spinedex Physical Therapy v. United Healthcare" on Justia Law

Plaintiffs filed suit against Deputy Arnold and Sheriff Graves, alleging violations of federal and state law after Arnold fatally shot their father while responding to a 911 call that the father was threatening to commit suicide. Plaintiffs also filed suit against ReliaStar to recover $179,000 they allege ReliaStar owes them under the father's accidental death policy. The district court granted Arnold and Grave's motions for summary judgment and granted ReliaStar's motion for summary judgment. The court held that Arnold did not violate the father's Fourth Amendment rights when he entered the father's home without a warrant because he had an objectively reasonable belief that the father would imminently seriously injure himself, and the district court did not err in granting Arnold's motion for summary judgment on the warrantless entry claim because Arnold is entitled to qualified immunity; Arnold is entitled to qualified immunity because he did not violate the father's constitutional right to be free from excessive force; the district court did not err in granting summary judgment for Arnold on the assault and battery claims, the false imprisonment claims, and the intentional infliction of emotional distress claim; the district court correctly granted Graves's motion for summary judgment; and the district court did not err in granting summary judgment for ReliaStar where the record was replete with factual evidence that ReliaStar relied on in determining that the father's death was not accidental, demonstrating that ReliaStar could have reached its determination without resorting to the conflict of interest at issue. Accordingly, the court affirmed the judgment of the district court. View "Rice, et al. v. Reliastar Life Ins. Co." on Justia Law

In 2005, Girl Scouts of the United States (GSUSA) chartered 312 councils until it combined them into 112 councils. It merged councils that did not participate in the National Girl Scout Councils Retirement Plan with participating councils and made about 1,850 nonparticipating employees eligible for a lifetime pension benefit without having previously contributed to the Plan. In 2006, GSUSA added the Voluntary Early Retirement Incentive Plan, enabling participants to subsidize and accelerate eligibility for their pensions. Girl Scouts of Middle Tennessee (GSMT) sued, claiming that the realignment and the early retirement amendment caused GSMT to incur massive new liabilities. As of 2007, the Plan had a surplus of over $150 million, but by 2011, it had a deficit close to $340 million. GSUSA implemented an increase of its councils’ contribution rates. GSMT wanted to withdraw from the Plan and form its own retirement plan. GSUSA would not grant GSMT permission to withdraw. GSMT sued under the Employee Retirement Income Security Act, federal and state common law, and Tennessee Code 48-53-104. The district court dismissed. The Sixth Circuit affirmed. GSMT has no claim under ERISA and the court declined to create federal common law. GSMT failed to properly plead its state law claim, which would fail as preempted by ERISA. View "Girl Scouts of Middle TN, Inc. v. Girl Scouts of U.S.A." on Justia Law

South Water Market and Local 703 of the Teamsters Union had a collective bargaining agreement that ran from 2004 through April 30, 2007. On September 12, 2007, they reached a new agreement. Abramson, Market’s bargaining representative, was supposed to draft the agreement. Murdoch, the Union’s president reminded Abramson repeatedly. By February 2008 Murdoch was worried that pension and welfare funds covering the employees would cut off participation or sue. In March, Abramson begged off, stating: “I’m having trouble with my notes.” On April 3 Murdoch sent Abramson a document with terms from Murdoch’s notes. Abramson did not reply, but Market began paying wages, and making pension and welfare contributions specified in Murdoch’s text. Murdoch also sent the document to the pension and welfare funds, which submitted bills calculated according to those terms. In July 2009 Castillo retired. He had been one of two workers in the highly-compensated “driver classification. The Murdoch document stated that Market would employ at least two drivers. After Castillo retired, it refused to provide more than one worker with the wages and benefits of the driver classification. The pension and welfare funds sued under the Employee Retirement Income Security Act, 29 U.S.C. 1145, seeking delinquent contributions for a second driver position. The district judge found that Market had not agreed to the terms. The Seventh Circuit reversed, reasoning that the Labor Management Relations Act makes a written agreement essential to participation in a pension or welfare plan, 29 U.S.C. 186(c)(5)(B), and Market does not contend that it wants to drop out of the plans or that it did withdraw Whatever reservations Abramson had were not conveyed to the funds until August 2009, much too late. View "Russ v. South Water Mkt, Inc." on Justia Law

Smith was an employee CGC, which offered some employees, including Smith, enhanced compensation if they would remain with CGC through its merger with AEGON. Under the Voluntary Employee Retention and Retirement Program (VERRP) Smith would retire in 2000. Smith elected to receive $1,066.54 under the qualified plan and $1,122.97 under the non-qualified plan, through the “AEGON USA Pension Plan: Election for Distribution and Explanation of Benefits.” An attachment informed Smith that “you will be entitled to receive additional benefits from the [CGC] Retirement Plan.” The two plans subsequently merged. Smith retired and the Plan paid him a lump sum plus $2,189.51 per month. In 2007, AEGON amended the Plan to add a “Restriction on Venue. A participant or Beneficiary shall only bring an action in connection with the Plan in Federal District Court in Cedar Rapids, Iowa.” In 2011, the Plan told Smith that it had overpaid him by $1,122.97 per month for 11 years and eliminated Smith’s entire monthly payment to obtain recoupment. Smith exhausted administrative remedies then filed suit against CGC in state court, asserting breach of contract, wage and hour statutory violations, estoppel, and breach of the duty of good faith and fair dealing. CGC removed the action to federal court, which dismissed, finding that that the VERRP was regulated by ERISA, that Smith was suing to recover benefits under this ERISA plan, and that only the Pension Committee, not CGC, was a proper defendant. The Sixth Circuit affirmed. Smith filed suit against the AEGON Plan in the U.S. District Court for the Western District of Kentucky. The district court dismissed based on the venue selection clause. The Sixth Circuit affirmed, upholding the venue selection clause as applying to all actions brought by a participant or beneficiary, not just claims for benefits. View "Roger Smith v. Aegon Companies Pension Plan" on Justia Law

Plaintiff filed suit against Reliance and the Plan, under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., claiming that Reliance abused its discretion in denying long-term disability benefits. The district court granted summary judgment to plaintiff. The court concluded that Reliance's interpretation of the Plan is reasonable. The loss-of-license provision states that the loss of a license for any reason is insufficient in and of itself to entitle a claim to benefits. In this case, plaintiff's diagnosis of diabetes mellitus was not enough by itself to justify benefits. Reliance's interpretation merely requires that the claimant show that the injury or sickness itself renders him unable to perform his occupation. Further, Reliance's determination that plaintiff was not totally disabled was supported by substantial evidence and its denial of benefits was reasonable. Accordingly, the court reversed the judgment of the district court. View "Hampton v. Reliance Standard Life Ins. Co." on Justia Law

Plaintiff received benefits under her employer’s long-term disability benefit plan before the administrator for the long-term disability program determined she was no longer eligible for benefits. The administrator denied Plaintiff’s appeal as untimely for her failure to appeal within the benefit plan’s 180-day deadline. Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), claiming that her failure to comply with the 180-day deadline should have been excused because the benefit plan’s written instrument did not mention the deadline. The district court dismissed Plaintiff’s benefits challenge as well as her two other ERISA claims for statutory penalties and for breach of fiduciary duty. The First Circuit affirmed, holding that the district court did not err in (1) dismissing Plaintiff’s benefits challenge, as Plaintiff failed to meet the deadline for appealing internally the decision to cut off her long-term disability benefits, and the benefit plan had expressly incorporated that deadline into the benefit plan’s written instrument; and (2) ruling that Plaintiff could not recover statutory penalties against the administrator or that she had waived her claim for breach of fiduciary duty. View "Tetreault v. Reliance Standard Life Ins. Co." on Justia Law