Justia U.S. 11th Circuit Court of Appeals Opinion SummariesArticles Posted in ERISA
Virgil Harris v. The Lincoln National Life Insurance Company, et al
Under the Employment Retirement Income Security Act, 29 U.S.C. Section 1132(a)(1)(B), a plan administrator’s benefits decision is subject to plenary review in federal court unless the administrator is given discretion to determine eligibility or construe the terms of the plan. If the administrator has discretion, a court determines whether its benefits decision was arbitrary and capricious (i.e., whether it lacked a reasonable basis). In this ERISA case, all parties agree that Lincoln’s denial of long-term disability benefits to Plaintiff triggered de novo review because the plan did not give Lincoln discretion. The district court, acknowledging that its review of the denial was plenary, ruled that Plaintiff could not submit evidence that had not been presented to Lincoln before it denied benefits. The Eleventh Circuit reversed holding that the district court’s evidentiary ruling constituted error under Eleventh Circuit precedent. The court explained that Lincoln also argues that even under Moon and Kirwan an ERISA plaintiff does not have the unfettered right to introduce new evidence when challenging the denial of benefits under plenary review. However, the court explained it has never mentioned, a showing of good cause to present new evidence in ERISA benefit cases governed by the de novo standard. Further, although Lincoln that under plenary review the administrative record supports the denial of long-term disability benefits to Plaintiff, the court cannot, however, affirm on this basis. Accordingly, the district court erred by not considering Plaintiff's post-denial evidence, and Lincoln does not assert that this error was harmless. View "Virgil Harris v. The Lincoln National Life Insurance Company, et al" on Justia Law
Raniero Gimeno v. NCHMD, Inc., et al.
Plaintiff’s spouse was a medical doctor employed by NCHMD, Inc., which is a subsidiary of NCH Healthcare System, Inc. NCHMD’s human resources staff helped the spouse complete enrollment paperwork for life insurance benefits through an ERISA plan. Plaintiff was the primary beneficiary under the plan, and NCH Healthcare was the named plan administrator. After Plaintiff’s spouse died, Plaintiff filed a claim for benefits with the plan’s insurance company. The insurance company refused to pay any supplemental benefits because it had never received the form. Plaintiff sued NCHMD and NCH Healthcare, asserting a claim under ERISA, 29 U.S.C. Section 1132(a)(1)(B). The district court granted Defendants’ motion to dismiss and denied Plaintiff leave to amend. On appeal, the Eleventh Circuit reversed the district court’s ruling. The court wrote that at issue is whether Section 1132(a)(3) creates a cause of action for an ERISA beneficiary to recover monetary benefits lost due to a fiduciary’s breach of fiduciary duty in the plan enrollment process? The court answered “yes”, and explained that under the court’s precedents, a court may order typical forms of equitable relief under Section 1132(a)(3). As the Supreme Court and many sister circuits have recognized, courts in equity could traditionally order an “equitable surcharge”— that a fiduciary pay a beneficiary for losses caused by the fiduciary’s breach of fiduciary duty. Accordingly, the court held that a beneficiary of an ERISA plan can bring a lawsuit under Section 1132(a)(3) against a fiduciary to recover benefits that were lost due to the fiduciary’s breach of its duties. View "Raniero Gimeno v. NCHMD, Inc., et al." on Justia Law
Klaas v. Allstate Insurance Co.
After Allstate decided to stop paying premiums on retired employees' life insurance policies, two putative classes filed suit seeking declaratory and injunctive relief. The Turner retirees are made up of retired former Allstate employees to whom Allstate no longer provides life insurance. The Klaas retirees consist of individuals who took part in a special retirement opportunity with Allstate.The Eleventh Circuit affirmed the district court's judgment in favor of Allstate, concluding that Allstate had the authority under the summary plan descriptions to terminate the retiree life insurance benefits for both putative classes and did not violate Section 502(a)(1)(B) of the Employee Retirement Income Security Act (ERISA). The court also concluded that any claims for breach of fiduciary duty brought under section 502(a)(3) were time barred. View "Klaas v. Allstate Insurance Co." on Justia Law
Sullivan v. Liberty Life Assurance Company of Boston
The Eleventh Circuit held that the Employment Retirement Income Security Act's (ERISA) fee-shifting provision, 29 U.S.C. 1132(g)(1), cannot support a fee award against a party's counsel. The court explained that the function of this statute is not to sanction attorney misconduct. Rather, that role belongs to other provisions, such as 28 U.S.C. 1927 and Federal Rule of Civil Procedure 11(c).In this case, the district court relied exclusively on Section 1132(g)(1) when awarding fees. Therefore, the court reversed and vacated the district court's fee award. The court did not address Liberty Life's argument that the district court should have imposed fees against Theresa E. Peer's counsel, Paul Sullivan. On remand, the district court may consider whether a fee award is appropriate against Peer under ERISA or against Peer or Sullivan under another statute, rule, or the district court's inherent authority. View "Sullivan v. Liberty Life Assurance Company of Boston" on Justia Law
Griffin v. Coca-Cola Refreshments USA, Inc.
Plaintiff, a dermatologist in Atlanta, Georgia, has filed many appeals in the Eleventh Circuit in recent years, all of which have involved her attempts to receive in-network payments despite being an out-of-network provider. These consolidated appeals arise from plaintiff's treatment of two patients who were insured under two separate employee welfare benefit plans which are administered by United. The Employee Retirement Income Security Act of 1974 (ERISA) covers both plans.The Eleventh Circuit affirmed the district court's dismissal of plaintiff's cases against Coca-Cola and Delta (defendants). The court concluded that, even assuming that waiver is available in the ERISA context, defendants did not waive their ability to assert the anti-assignment provisions as a defense. Furthermore, regardless of waiver, plaintiff's lawsuit still fails to state a claim: United paid her in full, both under the terms of the patients' assignments and the provisions of the healthcare plans. View "Griffin v. Coca-Cola Refreshments USA, Inc." on Justia Law
Pension Benefit Guaranty Corp. v. 50509 Marine LLC
The Eleventh Circuit held that, in the unusual circumstances of this case, Liberty still existed in 2012 sufficiently to act as the employee pension plan's sponsor under the Employee Retirement Income Security Act (ERISA). In this case, Liberty was an Illinois corporation that went bankrupt and dissolved under state law in the 1990s.The court followed the Supreme Court's instruction to fill in ERISA's gaps with common-law rules, and held that where the sponsor of an ERISA plan dissolves under state law but continues to authorize payments to beneficiaries and is not supplanted as the plan's sponsor by another entity, it remains the constructive sponsor such that other members of its controlled group may be held liable for the plan's termination liabilities. Under this narrow rule, the court held that the Companies are liable to PBGC for the Plan's termination liabilities for the simple reason that Liberty persisted as the Plan's sponsor even as it dissolved as an Illinois corporation. View "Pension Benefit Guaranty Corp. v. 50509 Marine LLC" on Justia Law
Hill v. Employee Benefits Administrative Committee of Mueller Group LLC
Plaintiff and 22 other employees filed suit under the Employee Retirement Income Security Act (ERISA), challenging the plan administrator's denial of Special Early Retirement (SER) benefits. Plaintiffs claim that they are entitled to SER benefits because the sale of the parent company's interests to another company effected either a layoff or a permanent plant shutdown. Before and after the sale, the factory remained continuously operational and the employees remained employed in their same jobs.The Eleventh Circuit affirmed the district court's denial of the ERISA benefits because plaintiffs were neither laid off nor terminated by a permanent plant shutdown and thus they were not entitled to SER benefits under the language of the plan. The court also held that plaintiffs cannot make out a claim for equitable relief because their alternative theory arises form the same factual circumstances as their first. View "Hill v. Employee Benefits Administrative Committee of Mueller Group LLC" on Justia Law
Crowder v. The Delta Air Line, Inc. Family-Care Savings Plan
After Marvin Crowder died, Fidelity disbursed his plan benefits to his sister as his designated beneficiary. Plaintiff, Marvin's ex-wife, filed suit under the Employee Retirement Income Security Act (ERISA), alleging claims of wrongful denial of benefits and breach of fiduciary duty.The Eleventh Circuit affirmed the district court's dismissal of plaintiff's ERISA claims, holding that the Plan Administrator correctly interpreted the Plan and that, after her divorce, plaintiff had no entitlement to her ex-husband's benefits under the Plan's terms. Because plaintiff was not a "beneficiary" under Section 14.03 of the Plan, she failed to state a plausible claim for wrongly denied benefits. Likewise, plaintiff's claims for breach of fiduciary duty failed because she was not a "beneficiary" under the Plan and defendants owed no ERISA-imposed duties to her. Furthermore, plaintiff also lacked statutory authorization to bring a claim for equitable relief based on defendants' alleged breach of their fiduciary duties. View "Crowder v. The Delta Air Line, Inc. Family-Care Savings Plan" on Justia Law
Williamson v. Travelport, LP
Plaintiff filed a class action against Travelport and the Galileo & Worldspan U.S. Legacy Pension Plan under the Employee Retirement Income Security Act of 1974, alleging claims for improperly withheld pension benefits, document-disclosure penalties, and breach of fiduciary duties. The district court dismissed all claims.With respect to plaintiff's claim for benefits, the Eleventh Circuit reversed and remanded for the district court to review her claim anew after Travelport has certified and submitted the complete and accurate administrative record. The court reversed the district court's award of attorney's fees, but otherwise affirmed the district court's judgment. View "Williamson v. Travelport, LP" on Justia Law
MetLife and Annuity Company of Connecticut v. Akpele
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