Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

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

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

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

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 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

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

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

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

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

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