Justia ERISA Opinion Summaries

Village Fuel appealed the district court's denial of attorney's fees in an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., action. The court concluded that Village Fuel obtained some degree of success on the merits in defeating GHI's restitution claims and that, under ERISA, a favorable court judgment was not required to satisfy the threshold of awarding attorney's fees. The court vacated and remanded to the district court for further proceedings to determine a reasonable amount of attorney's fees, if any, to be awarded to Village Fuel. View "Scarangella & Sons v. Group Health, Inc." on Justia Law

Unum denied plaintiff's claims of long-term disability and sought more than $1 million in reimbursements for benefits paid. Unum denial was based on emails it had received from plaintiff's former companion indicating that plaintiff was engaged in activities that were inconsistent with her asserted disability. The district court found that there was substantial evidence to support Unum's denial of benefits, but, nonetheless, held that the denial was procedurally unreasonable because Unum did not fulfill its duty to "consider the source" of the emails. The court concluded that, in evaluating whether a plan administrator wrongfully denied benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., it has never imposed a duty to investigate the source of the evidence. The court held that the burden was on the claimant to discredit evidence relied on by the plan administrator. Accordingly, the court reversed the judgment of the district court, finding that Unum did not act arbitrarily and capriciously in denying plaintiff benefits. View "Truitt v. Unum Life Ins. Co. of America" on Justia Law

In 1999 Brooks, an assembly-line operator for Prairie Packaging, was seriously injured on the job and lost his left hand, wrist, and forearm. He filed a workers’ compensation claim seeking recovery for permanent and total disability, which remains pending. Prairie treated Brooks as a disabled employee on a company-approved leave of absence, so that he continued to receive healthcare coverage. Pactiv acquired Prairie in 2007 and continued this arrangement. In 2010 Pactiv sent Brooks a letter instructing him to submit documents verifying his ability to return to work; failure to submit would mean termination of employment. Because his injury was totally disabling, Brooks did not submit verification and Pactiv fired him; he lost his healthcare coverage under the employee-benefits plan. Brooks sued Pactiv and Prairie under the Employee Retirement Income Security Act, 29 U.S.C. 1001–1461, for benefits due and breach of fiduciary duty and asserted an Illinois law claim for retaliatory discharge. The district court dismissed. The Seventh Circuit affirmed with respect to ERISA because Brooks did not allege that the employee-benefits plan promised him post-employment benefits. Pactiv acted as an employer, not as a fiduciary, in terminating Brooks’s employment and cancelling his health insurance. The court reinstated the state law claim. View "Brooks v. Pactiv Corp." on Justia Law

Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., after the Trustees' of their pension plan determined that plaintiffs' respective post-retirement jobs as traffic flagger and snow plow operator fell into the same "job classification" as their former union jobs as skilled mechanics. Therefore, plaintiffs were precluded from working these jobs if they wanted to collect retirement benefits. The court concluded that common sense strongly suggested that a position flagging traffic or plowing snow was not in the same "job classification" as a skilled mechanic repairing heavy equipment utilizing special skills acquired over a long career. The court reversed the district court's judgment because it was unable to see how any sensible application of the skills and duties test to the established facts could support the Trustees' conclusion. Accordingly, the court reversed the judgment. View "Tapley v. Locals 302 and 612" on Justia Law

Laskin worked for Jefco from 1966-1974 and participated in the company pension plan, accumulating a fully vested retirement account balance of $5,976.09. Soon after she left the company Laskin contacted Siegel, a trustee of the pension plan, and asked whether she could withdraw the funds to buy real estate. Siegel sent Laskin a letter explaining that her account would accrue interest at the passbook rate and that the plan had been amended in 1975, raising the retirement eligibility age from 55 to 65. Over the next 10 years, Laskin received statements, indicating that she was receiving from 5% to 5.5% interest on her balance. In 1988, a statement indicated that her balance was $12,602.86. The pension plan dissolved on December 31, 1991. In 2008, Laskin contacted Siegel’s son (who had purchased his father’s interest in Jefco) and was told that pension funds had been completely disbursed and that she did not receive a payout because she could not be located. The district court dismissed her claims as barred by the limitations period in the Employee Retirement Income Security Act, 29 U.S.C. 1113. The Seventh Circuit affirmed. View "Laskin v. Siegel" on Justia Law

Laskin worked for Jefco from 1966-1974 and participated in the company pension plan, accumulating a fully vested retirement account balance of $5,976.09. Soon after she left the company Laskin contacted Siegel, a trustee of the pension plan, and asked whether she could withdraw the funds to buy real estate. Siegel sent Laskin a letter explaining that her account would accrue interest at the passbook rate and that the plan had been amended in 1975, raising the retirement eligibility age from 55 to 65. Over the next 10 years, Laskin received statements, indicating that she was receiving from 5% to 5.5% interest on her balance. In 1988, a statement indicated that her balance was $12,602.86. The pension plan dissolved on December 31, 1991. In 2008, Laskin contacted Siegel’s son (who had purchased his father’s interest in Jefco) and was told that pension funds had been completely disbursed and that she did not receive a payout because she could not be located. The district court dismissed her claims as barred by the limitations period in the Employee Retirement Income Security Act, 29 U.S.C. 1113. The Seventh Circuit affirmed. View "Laskin v. Siegel" on Justia Law

Plaintiffs filed suit against their former employer seeking deferred compensation payments. The district court held that plaintiffs' deferred compensation arrangements in their Employment Agreement contracts with the employer constituted a plan under the Employment Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Because plaintiffs' deferred compensation arrangements did not necessitate an ongoing administrative scheme, there was no ERISA plan. Accordingly, the court reversed and remanded, concluding that plaintiffs' state law claims were not preempted by ERISA. View "Cantrell, et al. v. Briggs & Veselka Co." on Justia Law

Debtor was required to make contributions to the Carpenters Pension Trust Fund pursuant to a multiemployer bargaining agreement (the Agreement). When the Agreement expired, debtor no longer was a signatory to a collective bargaining agreement and stopped making payments. The Fund subsequently filed suit because debtor was still doing work covered by the Agreement and was subject to withdrawal liability under 29 U.S.C. 1381. Debtor then filed for bankruptcy and sought a discharge of his debt to the Fund. The Fund filed a complaint under 11 U.S.C. 523(c) to prevent discharge, seeking to establish that the debt qualified as one created via defalcation by a fiduciary under section 523(a)(4). The court concluded that the Bankruptcy Court had jurisdiction to adjudicate the dischargeability of the Fund's claim against debtor; debtor was not a fiduciary of the Fund because the unpaid withdrawal liability was not an asset of the Fund; and debtor's failure to challenge the withdrawal liability amount in arbitration did not act as a waiver of his right to discharge the debt. Accordingly, the court affirmed the judgment. View "Carpenters Pension Trust Fund v. Moxley" on Justia Law

Appellant was placed on disability leave from work. Appellant was covered under a long term disability (LTD) policy that her employer obtained from Medical Group Insurance Services (MGIS). The policy was written by Sun Life Assurance Company (Sun Life). After leaving her job, Appellant filed a claim with MGIS seeing long term disability benefits. Sun Life denied Appellant's request for benefits. Appellant filed an action against Sun Life, asserting various state law claims. The federal district court dismissed the action based on ERISA preemption. Appellant then amended her complaint to add ERISA claims and asked the district court to apply de novo review in its evaluation of her ERISA claims. The court denied the motion and granted summary judgment for Sun Life, concluding that Sun Life's decision to deny benefits was not arbitrary and capricious, and thus complied with ERISA's requirements. The First Circuit Court of Appeals vacated the judgment, holding (1) the safe harbor exception to ERISA did not apply to the policy covering Appellant, and therefore, Appellant's state law claims were preempted; but (2) the benefits denial was subject to a de novo review, rather than the highly deferential "arbitrary and capricious" review prescribed for certain ERISA benefits decisions. Remanded. View "Gross v. Sun Life Assurance Co. of Canada" on Justia Law

Retirees, dependents of retirees, and the union filed a class action suit against the retirees’ former employer, M&G, after M&G announced that they would be required to make health care contributions. The district court found M&G liable for violating a labor agreement and an employee welfare benefit plan and ordered reinstatement of the plaintiffs to the current versions of the benefits plans they were enrolled in until 2007, to receive health care for life without contributions. The Sixth Circuit affirmed. The district court properly concluded that the retirees’ right to lifetime healthcare vested upon retirement after concluding that documents, indicating agreement between the union and the employers to “cap” health benefits and several “side” letters were not a part of the applicable labor agreements. View "Tackett v. M&G Polymers USA, LLC," on Justia Law