Justia ERISA Opinion Summaries

Plaintiff, who worked for Metropolitan Life Insurance Co. (“MetLife”), made a claim for long-term disability benefits (LTD). In 2005, the claim was approved. That same year, MetLife denied Plaintiff’s assertion that he was entitled to a larger payment calculation. In 2012, Plaintiff filed suit against MetLife under the Employee Retirement Income Security Act of 1974 (ERISA), claiming that MetLife had been underpaying his monthly benefits since 2005. The district court granted MetLife’s motion for summary judgment, concluding that Plaintiff’s suit was barred by the six-year statute of limitations. The First Circuit Court of Appeals affirmed, thus rejecting Plaintiff’s theory that the LTD plan must be analogized to an installment plan so as to alter the accrual date of his claim, holding that Plaintiff’s claim against MetLife was barred by the statute of limitations. View "Riley v. Metro. Life Ins." on Justia Law

The employers were formerly contributing members of the Teamsters Local Union No. 293 Pension Plan. In 2007-2008 each employer reached an agreement with the Plan to terminate its membership. They were required to pay, and have paid, “withdrawal liability” reflecting each employer’s share of unfunded, vested pension benefits under the Multiemployer Pension Plan Amendments Act, 29 U.S.C. 1381–1461. Under the Act, if the plan is terminated altogether by a “mass withdrawal” of the remaining members within three years, the earlier withdrawing members may be subject to additional “reallocation liability.” Disputes about the amount of such reallocation liability are subject to mandatory arbitration. The employers claim that a 2009 mass withdrawal was expedited to occur within the three-year period in order that they would be subject to reallocation liability. The Plan trustees sought more than $12 million in additional funds from the employers. The district court dismissed their suit for failure to complete arbitration. The Sixth Circuit affirmed. The Act requires that the claim of “sham” mass withdrawal be arbitrated. View "Knall Beverage, Inc. v. Teamsters Local Union No. 293 Pension Plan" on Justia Law

Plaintiffs filed suit alleging violations of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs claimed that the bonds that they invested in were an unsuitable investment for the Plans' funds and that defendant made multiple oral misrepresentations to plaintiffs in violation of his fiduciary duties. The district court ruled that there was a disputed issue of material fact as to whether defendant was an ERISA fiduciary, but nonetheless granted summary judgment because defendant provided plaintiffs with written disclosures. The court concluded that defendant did not qualify as a fiduciary under ERISA subsection 1002(21)(A)(i) because he did not exercise discretionary authority or control over the investment at issue; subsection 1002(21)(A)(ii) because he did not receive a fee from the Plans in connection with the investment; and section 1002(21)(A)(iii) because it was inapplicable in this instance. Accordingly, the court affirmed the judgment of the district court. View "Tiblier, et al. v. Dlabal, et al." on Justia Law

Plaintiff appealed the Rule 12(b)(1) dismissal of her putative class action complaint brought under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court concluded that, based on the record to date and at this Rule 12(b)(6) juncture, the district court erred in finding that the three-year limitations period applied to plaintiff's claims in Count 2. The court concluded, however, that plaintiff's claims in Count 2 were time-barred by ERISA's six-year period of limitations. Accordingly, the court affirmed the judgment of the district court. View "Fuller v. SunTrust Banks, Inc., et al." on Justia Law

Dr. Charles Dahl and Ms. Kim Dahl divorced in 2010. Ms. Dahl filed suit in the United States District Court for the District of Utah, alleging federal-law and state-law claims stemming from the terms of the divorce: (1) that Dr. Dahl improperly administered the pension trust of his medical practice to deny her funds and an accounting and (2) that her telephone conversations with the Dahls’ minor children were unlawfully monitored, recorded, and disclosed by Dr. Dahl, his attorney, and the children’s guardian ad litem (GAL) in the divorce proceedings. The district court dismissed the federal-law pension claims for lack of subject-matter jurisdiction and granted summary judgment against Ms. Dahl on the federal-law wiretapping claims. It then declined to exercise jurisdiction on the state-law claims. Ms. Dahl appealed. Upon review, the Tenth Circuit: affirmed the district court’s dismissal of Ms. Dahl’s pension claims on the ground that the pension trust did not qualify as an employee benefit plan under ERISA, but that the claim should have been on the merits rather than for lack of jurisdiction. The Court affirmed the district court in all other respects. View "Dahl v. Dahl, et al" on Justia Law

The Commission appealed the district court's order preliminarily enjoining him from enforcing several provisions of the Georgia Code as preempted by Section 514 of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1144(a). The court found that AHIP had standing to challenge Section 4, 5, and 6 of the Insurance Delivery Enhancement Act of 2011 (IDEA), O.C.G.A. 33-24-59.5; AHIP's suit was not barred by the Tax Injunction Act, 28 U.S.C. 1341; AHIP was likely to succeed on the merits of its claims where the challenged IDEA provisions were preempted by ERISA Section 514; and the district court did not abuse its discretion in concluding that AHIP met its burden to show irreparable injury and that the balance of equities weighed in favor of a preliminary injunction. Accordingly, the court affirmed the judgment of the district court. View "America's Health Ins. Plan v. Hudgens" on Justia Law

Richard worked for GPI for 25 years until his 2009 death. He had a basic life insurance policy through GPI’s health and welfare plan and paid for an optional supplemental life insurance policy through GPI for several years. His wife, Maureen, was the beneficiary of both policies. At the end of 2008, Richard’s supplemental life insurance policy was cancelled. Richard’s pay stubs reflected the change, beginning in January 2009. When Richard died a few months later, GPI’s insurer, ABC, paid benefits on the basic life insurance policy. Richard had been diagnosed with stage 4 cancer in September 2008. Soon after Richard’s death, Maureen’s attorney requested information regarding Richard’s supplemental life insurance policy. The company refused the request, citing its confidentiality policy, indicating that the information would only be produced in response to a subpoena. Almost two years later, Maureen filed suit, claiming that either GPI or ABC breached the policy by terminating it without Richard’s consent, in violation of the Employee Retirement Income Security Act, 29 U.S.C. 1001. The district court awarded the defendants summary judgment. The Seventh Circuit affirmed. There was no material issue of fact as to whether Richard cancelled his supplemental policy. Although Maureen speculated that someone other than Richard terminated the policy, she presented no evidence to support her assertion. View "Herzog v. Graphic Packaging Int'l, Inc." on Justia Law

Plaintiff appealed the district court's entry of summary judgment in favor of Open Harvest on plaintiff's claim alleging a violation of section 510 of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1140. Because plaintiff has not identified direct evidence of a specific intent to interfere with her ERISA benefits, the court must analyze her claim under the McDonnell Douglas burden-shifting framework. In this case, Open Harvest articulated a legitimate, non-discriminatory justification for its failure to pay the August policy premium. Under the McDonnell Douglas framework, the burden shifted back to plaintiff to show a genuine dispute whether Open Harvest's justification was pretextual. Plaintiff failed to show a genuine dispute whether Open Harvest terminated her employment with a specific intent to interfere with her ERISA benefits. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Open Harvest. View "Barnhardt v. Open Harvest Cooperative" on Justia Law

An employee benefits plan sued a medical college that provides patient care in clinics and hospitals and an affiliated children’s hospital, with which it had provider agreements, alleging ERISA violations and breach of contract under Wisconsin law. The suit was based on the plan’s determination that an employee’s child was not covered by the plan and the hospital’s denial of its subsequent request that the hospital refund about $1.7 million the plan had already paid on behalf of the child. The plan makes no mention of refunds. The district court dismissed and awarded attorneys’ fees to the hospital as a sanction for having filed frivolous claims. The Seventh Circuit affirmed dismissal of the ERISA claims but reversed dismissal of the breach of contract claim, rejecting the district court’s finding of preemption, and imposition of sanctions. On remand of the contract claim, the district court granted summary judgment in favor of the hospital. The Seventh Circuit affirmed, noting that the hospital, having been paid in full by the plan, has no possible claim against Medicaid, that the plan took 11 months to determine that the child was not a beneficiary, and that the hospital has not been unjustly enriched. View "Kolbe & Kolbe Health & Welfare Benefit Plan v. Med. Coll. of WI" on Justia Law

A Vermont statute requires all "health insurers" to file with the State reports containing claims data and other "information relating to health care." Liberty Mutual sought a declaration that the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., preempted the Vermont statute and regulation. The district court granted summary judgment in favor of Vermont. The court held that the reporting requirements of the Vermont statute and regulation have a "connection with" ERISA plans and were therefore preempted as applied. The court's holding was supported by the principle that "reporting" is a core ERISA function shielded from potentially inconsistent and burdensome state regulation. Accordingly, the court reversed and remanded with instructions to enter judgment for Liberty Mutual. View "Liberty Mutual Ins. Co. v. Donegan" on Justia Law