Articles 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

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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

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The PAPER COMPANY's creditors successfully petitioned the Bankruptcy Court for relief under Chapter 7 of the Bankruptcy Code. The Bankruptcy Court then granted the PAPER COMPANY's motion to transform the Chapter 7 case into a Chapter 11 proceeding. While the Chapter 11 case was pending, the PBGC brought an action against the PAPER COMPANY. At issue on appeal was whether, under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., the trustee of a corporation that is a contributing sponsor and is in bankruptcy can maintain an action for the benefit of the bankruptcy estate and the estate's unsecured creditors against the corporation's former owner (as a former member of the controlled group) for liabilities arising from the termination of a pension plan. The court held that the answer is no. The court concluded that ERISA's funding requirements were put in place for the benefit of plan beneficiaries, not for the protection of a bankrupt plan sponsor's unsecured creditors. The trustee's complaint failed to state a claim for relief because it was brought for the benefit of the bankrupt's unsecured creditors. View "Durango-Georgia Paper Co., et al. v. H.G. Estate, LLC, et al." on Justia Law

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Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., alleging that LINA violated the disability insurance policy's terms and ERISA requirements - in part because LINA ignored the SSA process and the information it generated. The district court granted summary judgment in favor of LINA. Because LINA did not have the evidence presented to the SSA when it denied her last appeal - and in fact could not have had that evidence when it initially denied her claim - the court vacated the district court's judgment and remanded the case with instructions to remand plaintiff's claims to LINA for its consideration of the evidence presented to the SSA. View "Melech v. Life Ins. Co. of North America, et al." on Justia Law