Articles Posted in ERISA

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Metlife initiated this interpleader action under Federal Rule of Civil Procedure 22, seeking to pay into the registry of the district court the proceeds of an insurance policy on the life of the deceased. Defendants were the deceased's widow, a minor child of the deceased, and the temporary administrator of the estate. The deceased purchased the policy at issue to fund the Plan he had established as its sole member and trustee pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The Eleventh Circuit held that MetLife deposited the proper amount into the district court registry and therefore affirmed the district court's order to the extent it addressed that issue. The court also held that the district court properly denied the administrator's renewed motion to enforce the settlement. However, the court remanded the action to the district court to address the issue of attorney fees in the first instance. View "MetLife and Annuity Company of Connecticut v. Akpele" on Justia Law

Posted in: ERISA

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Metlife initiated this interpleader action under Federal Rule of Civil Procedure 22, seeking to pay into the registry of the district court the proceeds of an insurance policy on the life of the deceased. Defendants were the deceased's widow, a minor child of the deceased, and the temporary administrator of the estate. The deceased purchased the policy at issue to fund the Plan he had established as its sole member and trustee pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The Eleventh Circuit held that MetLife deposited the proper amount into the district court registry and therefore affirmed the district court's order to the extent it addressed that issue. The court also held that the district court properly denied the administrator's renewed motion to enforce the settlement. However, the court remanded the action to the district court to address the issue of attorney fees in the first instance. View "MetLife and Annuity Company of Connecticut v. Akpele" on Justia Law

Posted in: ERISA

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Section 1113(1)'s statute of repose in the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 11131(a), is subject to express waiver. In this interlocutory appeal, the Eleventh Circuit was asked to answer a certified question regarding whether defendant was capable of expressly waiving the six-year statute of repose pursuant to section 1113(1). The court answered the certified question in the affirmative. The court reasoned that, because section 1113(1) does not erect a jurisdictional bar, it was presumptively waivable. Moreover, the court explained that there was no good reason to conclude that section 1113(1) cannot be expressly waived simply because it is a statute of repose. The court remanded for further proceedings. View "Secretary, U.S. Department of Labor v. Preston" on Justia Law

Posted in: ERISA

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WestRock filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., challenging an action taken by the Pace Industry Union-Management Pension Fund's Board of Trustees. The district court agreed with the Fund that ERISA provided no cause of action and granted the Fund’s motion to dismiss the complaint. The Eleventh Circuit affirmed, holding that WestRock has not properly alleged that the Amendment (the Fund's rehabilitation plan) violates 29 U.S.C. 1085 in a manner sufficient to bring a cause of action under Subsection B of 29 U.S.C. 1132(a)(10). Furthermore, the text of 29 U.S.C. 1451(a) does not support WestRock's reading that the Amendment imposes an additional liability on WestRock if it withdraws and therefore section 1451(a) provides it with a cause of action to challenge the Amendment. View "WestRock RKT v. Pace Industry Union" on Justia Law

Posted in: ERISA

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Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., seeking benefits for continued partial hospital treatment for her anorexia, which were denied on the ground that the level of care she sought was not medically necessary. On appeal, plaintiff challenged the district court's grant of summary judgment for Oxford. After careful consideration of the parties’ briefs, the record in the case, and with the benefit of oral argument presented to the court, the court concluded that the district court correctly decided that the record of the external review is properly before the district court in this ERISA case. However, the court concluded that the district court erred in holding that the adverse external review decision barred plaintiff from presenting her challenge to the adverse medical necessity determination. Because the external review process does not conflict with ERISA, it is not preempted. Accordingly, the court affirmed in part, reversed in part and remanded for further proceedings. View "Alexandra H. v. Oxford Health Ins." on Justia Law

Posted in: ERISA

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In these consolidated appeals, plaintiffs claimed that defendants breached their fiduciary duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001, et seq. While the appeals were pending, the Supreme Court issued its decision in Tibble v. Edison International, which held that a plaintiff can effectively allege that a defendant breached its duty of prudence under ERISA "by failing to properly monitor investments and remove imprudent ones[,] . . . [and] so long as the alleged breach of the continuing duty occurred within six years of suit, the claim is timely." The parties agreed that these cases should be remanded in light of Tibble. The court agreed and therefore vacated the judgments and remanded for further proceedings. The court declined to reassign the case to a new district judge. View "Pruitt v. Suntrust Banks, Inc." on Justia Law

Posted in: ERISA

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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

Posted in: ERISA

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After defendant Elem suffered injuries in a car accident, she and her attorney conspired to hide and disburse settlement funds from an employee welfare benefit plan she received after the accident. The parties filed cross motions for summary judgment and the district court granted summary judgment for the employer, as well as awarded attorney's fees and costs to the employer. The court affirmed, concluding that the district court had the authority to sanction defendants for their bad faith. The court also concluded that defendant's claim that the district court misapplied Federal Rule of Civil Procedure 70 was moot and dismissed the appeal. View "AirTran Airways, Inc. v. Elem, et al." on Justia Law

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In 2000, physicians and physician associations imitated a group of class actions against various providers of health plans, which were consolidated into a multidistrict litigation. This appeal involves this complex, twelve-year-old multidistrict litigation, a related multidistrict litigation pending in another federal district, and whether the district court reasonably interpreted the Settlement Agreement in the first action. The court affirmed the Injunction as to plaintiffs' Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961, and antitrust claims and as to the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1001 et seq., claims based on the denial or underpayment of benefits following the Settlement Agreement's Effective Date. On remand, the district court will need to determine which of plaintiffs' ERISA claims fall on the permissible side of the line, and reconsider the assessment of sanctions. View "Medical Assoc. of GA, et al. v. Wellpoint, Inc." on Justia Law

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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