Justia ERISA Opinion Summaries

Plaintiff, the Chairman of the Trustees of the Rhode Island Bricklayers Benefits Funds (the Funds), sued Union Stone Inc., alleging that Union Stone had failed to pay the full amount of fringe benefit contributions due for work performed in Massachusetts and Connecticut by members of the International Union of Bricklayers and Allied Craftworkers pursuant to a collective bargaining agreement. After a trial, the district court entered judgment in favor of the Funds, awarding the unpaid contributions, interest, and attorneys' fees. The First Circuit Court of Appeals affirmed, holding that the district court did not err in (1) refusing to enforce a purported settlement agreement between the parties; (2) admitting certain evidence on the ground that it was tainted by violations of the discovery rules; (3) declined to impose sanctions; and (4) awarding interest and attorneys' fees.View "Enos v. Union Stone, Inc." on Justia Law

Plaintiffs filed suit against the Plan under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1054(g). At issue was whether the anti-cutback rule in section 204(g) precluded plan amendments that reduced retirement-type subsidiaries for plan participants who have ceased employment without satisfying the preamendment conditions for the subsidy, but who could later satisfy the preamendment conditions without returning to work. The court held that the rule protected such benefits. Plaintiffs have satisfied the preamendment conditions and their benefits were protected by the anti-cutback rule. Accordingly, the court affirmed the judgment of the district court. View "Alcantara v. Bakery and Confectionery Union" on Justia Law

Plaintiffs worked until 2006, when the plant closed, and retired under a collective bargaining agreement (CBA); that provided that the employer would provide health insurance, either through a self-insured plan or under a group insurance policy and identified the employer’s contribution to the premium. The CBAs provided that the coverage an employee had at the time of retirement or termination at age 65 or older other than a discharge for cause “shall be continued thereafter provided that suitable arrangements for such continuation[] can be made… In the event… benefits … [are] not practicable … the Company in agreement with the Union will provide new benefits and/or coverages as closely related as possible and of equivalent value." In 2011 TRW (the employer’s successor) stated that it would discontinue group health care coverage beginning in 2012, but would be providing “Health Reimbursement Accounts” (HRAs) and would make a one-time contribution of $15,000 for each eligible retiree and eligible spouse in 2012, and in 2013, would provide a $4,800 credit to the HRAs for each eligible party. The HRAs shifted risk, and potentially costs, to plaintiffs. TRW did not commit to funding the HRAs beyond 2013. Plaintiffs sued, claiming that the change breached the CBAs, in violation of the Labor-Management Relations Act, 29 U.S.C. 185, and the Employee Retirement Income Security Act, 29 U.S.C. 1001. The district court certified a class and granted summary judgment, ruling that the CBAs established a commitment to lifetime health care benefits. The Sixth Circuit affirmed View "United Steel, Paper, Forestry, Rubber, Mfg. Energy, Allied Indus. & Serv. Workers Int'l Union v. Kelsey-Hayes Co." on Justia Law

Plaintiff was hired by Employer in 1983. Plaintiff was covered by a short-term disability plan, and the Life Insurance Company of North America (“LINA”) had the authority to decide questions of eligibility for coverage or benefits under the plan. After Plaintiff underwent back surgery in 2009, LINA at first granted but then denied Plaintiff disability benefits. In 2010, Plaintiff sued LINA, Employer, and others in Puerto Rico court, seeking review of the benefits denial. LINA later removed the action to the District of Puerto Rico. Ultimately, the district court (1) found LINA’s decision was not arbitrary and capricious because Plaintiff failed to produce sufficient medical evidence of disability, and (2) dismissed Plaintiff’s claim against Employer for failure to plead it with specificity. Plaintiff appealed. The First Circuit Court of Appeals dismissed Plaintiff’s appeal on procedural grounds because Plaintiff committed numerous procedural errors, which precluded intelligent review. View "Gonzalez-Rios v. Hewlett Packard PR Co." on Justia Law

Plaintiffs filed suit against Lowe's challenging the Plan Administrator's denial of benefits under an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., Plan. The court reversed the district court's grant of relief from the denial of benefits and award of benefits because the court found that the Plan Administrator did not abuse its discretion where the Plan Administrator was not operating under a conflict of interest and was vested with the power to interpret the terms of the Plan.View "Porter v. Lowe's, et al." on Justia Law

Plaintiffs filed suit against their former employer and others under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. After the district court adopted the magistrate judge's recommended dispositions, plaintiffs appealed. The court concluded that plaintiffs have failed to set forth sufficient evidence to show that they were due more in benefits and penalties than the amount that the district court determined that they were owed; the district court did not abuse its discretion in denying their requests for nonmonetary relief or in determining the reasonable attorney's fees and costs; and, therefore, the court affirmed the judgment of the district court.View "McDowell, et al. v. Price, et al." on Justia Law

After Respondent resigned as executive director of the Chamber of Commerce, he filed a complaint against the Chamber, alleging violations of the Wage Payment and Collection Law, among other claims. After a jury trial, the court entered judgment against the Chamber. Respondent subsequently filed a motion for an award of attorneys' fees under the Wage Payment and Collection Law. The circuit court denied Respondent's motion on remand after applying a fee-shifting analysis from ERISA cases. The court of special appeals reversed the denial of the motion, holding that the circuit court erred in applying the ERISA factors. The Court of Appeals affirmed, holding that because ERISA and the Wage Payment and Collection Law serve distinct purposes and because their fee-shifting provisions are based on different principles, a trial court should not employ the ERISA fee-shifting test in deciding whether to award attorneys' fees. View "Ocean City Chamber of Commerce v. Barufaldi" on Justia Law

Plaintiff appealed the district court's summary judgment in favor of the Plan based on her failure to file the action within the applicable limitation period. The court concluded that plaintiff's right to file an Employee Retirement Income Security Act of 1974, 29 U.S.C. 1001 et seq., action accrued no later than the date her administrative appeal option expired, May 4, 2004, but plaintiff did not file the pending complaint until January 31, 2011. Therefore, the district court correctly concluded that plaintiff's action was barred by the four-year statute of limitation. The court held that the statue of limitations was not revived. Reviving a limitation period when an insurance company reconsiders a claim after the limitation period has run would discourage reconsideration by insurers even when reconsideration might be warranted. The court rejected plaintiff's estoppel and waiver claims. Accordingly, the court affirmed the judgment of the district court. View "Gordon v. Deloitte and Touche" on Justia Law

Nicole discovered Shawn’s body in their Ohio home. Shawn had gone out drinking the night before, while Nicole spent the night at a friend’s house. The Medical Examiner’s Office reported the cause of death as “[a]sphyxia by extreme and restricted position (positional asphyxia)” and the manner of death as “[a]cute ethanol intoxication ... ACCIDENT: Prolonged and extreme hypertension of neck and torso while intoxicated.” Shawn’s blood-alcohol level at the time of autopsy was .22%. Nicole filed a $212,000 claim for accidental-death benefits with the Plan, which covers “injury” as a result of an “accident,” defined as “an unintended or unforeseeable event or occurrence which happens suddenly and violently.” No benefits will be paid if the “Covered Person [is] deemed and presumed, under the law of the locale … to be under the influence of alcohol or intoxicating liquors.” Nationwide directed denial of Nicole’s claim, citing Exclusion 12, but quoting an earlier version that provided: “The Covered Person being deemed and presumed … to be driving or operating a motor vehicle while under the influence…” Later, based on amended Exclusion 12, Nationwide upheld the denial; its appeals panel affirmed. Nicole filed suit, asserting claims under the Employee Retirement Income Security Act and a common-law breach-of-fiduciary-duty claim. The district court entered judgment in favor of the defendants, but agreed with Nicole that the appeals panel had breached its statutory duty to provide her with Plan-related documents upon written request, and imposed a penalty of $55 per day ($8,910). The Sixth Circuit affirmed. View "Cultrona v. Nationwide Life Ins. Co." on Justia Law

GM provides its salaried retirees with continuing life insurance benefits under an ERISA-governed plan. MetLife issued the group life insurance policy and periodically sent letters to participants advising them of the status of their benefits. The plaintiffs, participants in the plan, allege that those letters falsely stated that their continuing life insurance benefits would remain in effect for their lives, without cost to them. GM reduced their continuing life insurance benefits as part of its 2009 Chapter 11 reorganization. The plaintiffs sued MetLife under the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1132(a)(2) & (a)(3) and state law. The district court dismissed. The Sixth Circuit affirmed. MetLife did not tell participants that the benefits were fully paid up or vested upon retirement, but that their benefits would be in effect for their lifetimes, which “was undeniably true under the terms of GM’s then-existing plan.” The court rejected claims of estoppel, of breach of fiduciary duty, unjust enrichment, breach of plan terms, and restitution.View "Merrill Haviland v. Metro. Life Ins. Co." on Justia Law