Articles Posted in ERISA

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The Eighth Circuit affirmed the district court's grant of summary judgment against plaintiff in an action seeking funds from her husband's trust that was transferred from an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001-1461, plan. The husband had requested the "Accrued Benefit" amount from his ERISA employee-benefit plan be transferred to his trust days before he passed away. Applying an abuse of discretion standard to this case, the court held that the plan administrative committee reasonably explained its interpretation and relied on substantial evidence to deny plaintiff's claim. Therefore, the committee did not abuse its discretion when it determined that the relevant inquiry was not when funds were received by a participant, but rather when funds were transferred out of the plan. View "Wengert v. Rajendran" on Justia Law

Posted in: ERISA, Trusts & Estates

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The Eighth Circuit affirmed the district court's grant of summary judgment against plaintiff in an action seeking funds from her husband's trust that was transferred from an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001-1461, plan. The husband had requested the "Accrued Benefit" amount from his ERISA employee-benefit plan be transferred to his trust days before he passed away. Applying an abuse of discretion standard to this case, the court held that the plan administrative committee reasonably explained its interpretation and relied on substantial evidence to deny plaintiff's claim. Therefore, the committee did not abuse its discretion when it determined that the relevant inquiry was not when funds were received by a participant, but rather when funds were transferred out of the plan. View "Wengert v. Rajendran" on Justia Law

Posted in: ERISA, Trusts & Estates

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The Eighth Circuit affirmed the district court's grant of summary judgment in favor of ConAgra in an action seeking to recover severance benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that ConAgra's financial conflict of interest was still a relevant factor the court considered in determining whether ConAgra abused its discretion in denying plaintiff's claim; ConAgra did not abuse its discretion in determining that plaintiff lacked good reason to self-terminate; and because ConAgra's decision was reasonable, ConAgra did not abuse its discretion in denying plaintiff's claim for benefits. Furthermore, ConAgra did not breach its fiduciary duty to plaintiff by misstating or omitting certain material information when communicating with him. Finally, the court held that plaintiff's claims were not frivolous and affirmed the award of attorney's fees incurred by plaintiff. View "Boyd v. ConAgra Foods, Inc." on Justia Law

Posted in: ERISA

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Plaintiff filed suit against UHS under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132, seeking to recover unpaid benefits. The Eighth Circuit held that plaintiff could not bring claims for benefits due to her husband in her personal capacity, but rather, a legal representative of her husband's estate must bring the claim. Furthermore, plaintiff could not bring a section 1132(a)(3)(B) claim in equity. However, a restitutionary claim for premiums she paid under section 1132(a)(3)(B) was potentially available to her if there was a plan violation. The court remanded to the district court to determine initially if there was such a plan violation and, if so, whether restitution of plaintiff's premiums was "appropriate equitable relief" under section 1132(a)(3)(B). The court also held that the district court did not err in determining that UHS was not the plan administrator and plaintiff's breach of contract claim was preempted by ERISA. View "Ibson v. United Healthcare Services" on Justia Law

Posted in: ERISA

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Plaintiffs filed suit against defendants, challenging the management of a defined benefit pension plan under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs alleged that defendants violated sections 404, 405, and 406 of ERISA by breaching their fiduciary obligations and causing the Plan to engage in prohibited transactions with a U.S. Bank subsidiary, FAF Advisors. The Eighth Circuit affirmed the district court's dismissal of the case as moot based on the Plan's overfunded status where there was no actual or imminent injury to the Plan itself that caused injury to plaintiffs' interests; dismissal of the Equities Strategy claim on statute-of-limitations and pleading grounds; and dismissal of plaintiffs' motion for attorneys' fees and costs. View "Thole v. U.S. Bank" on Justia Law

Posted in: ERISA

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Twin City filed suit seeking to recover unpaid fringe-benefit contributions allegedly due under a collective bargaining agreement (CBA). The district court granted summary judgment for the Association on the ground that WQS was precluded by a previous lawsuit from disputing liability for the contributions as an alter ego of a signatory of the agreement. The Eighth Circuit affirmed the district court's determination that WQS was liable for the unpaid fringe-benefit contributions where all of the elements required to apply issue preclusion were present. The court held that the Association has a right to collect contributions under the CBA, but that two categories of damages were not authorized by the Employee Retirement and Income Security Act, 29 U.S.C. 1132, 1145, and that the award should be reduced accordingly. The court also upheld the district court's grant of injunctive relief. The court remanded for the district court to exclude contributions due to the Working Fee and Industry Fund from the damages award, and to reduce the award of interest accordingly. View "Twin City Pipe Trades Service Assoc. v. Wenner Quality Services, Inc." on Justia Law

Posted in: ERISA

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The Fund filed suit against defendants under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(3), alleging that it had a right to a portion of a negligence settlement attributable to medical expenses. The Eighth Circuit affirmed the district court's grant of summary judgment for the Fund, considering defendants' admissions that the settlement agreements included the claim for medical expenses. Therefore, the Fund was entitled to whatever was recovered for medical expenses in the settlement action. View "Mackey v. Johnson" on Justia Law

Posted in: ERISA

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Jacob Plassmeyer incurred medical expenses during a collegiate baseball practice, and his college provided its student athletes insurance with FA. Jacob's father was also insured by the Dakotas, an employee welfare benefit plan, and Jacob was covered under this Employee Retirement Income Security Act (ERISA) plan as a dependent of his father. In this case, the trustees of Dakotas brought this declaratory judgment action against FA under section 502(a)(3) of ERISA, 29 U.S.C. 1132(a)(3), seeking an order enforcing the coordination of benefits (COB) provisions in the Dakotas plan by declaring that FA's policy provided primary coverage of Jacob's claim for medical expenses already incurred. The district court denied FA's motion to dismiss and granted Dakotas' motion for summary judgment. The Eighth Circuit held that a declaratory judgment action to enforce the Dakotas plan as it applied to the claim for benefits was both consistent with the plain language of section 502(a)(3), as construed in light of historical equitable remedies available to trustees; the court agreed with the district court that FA's coverage was primary; but the district court abused its discretion in awarding attorney fees. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Dakotas and Western Minnesota Electrical Industry Health & Welfare Fund v. First Agency, Inc." on Justia Law

Posted in: ERISA, Insurance Law

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The Eighth Circuit affirmed MetLife's denial of long term disability (LTD) benefits to plaintiff under a group insurance plan sponsored by her former employer pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that plaintiff presented no evidence of factors tending to demonstrate a consequential conflict of interest, or other indicia of biased decision making; the district court did not err by using an abuse of discretion standard of review; and MetLife did not abuse its discretion by denying LTD benefits to plaintiff where it properly considered all medical records, APS reports, comments, and other information submitted by plaintiff and her physicians. View "Cooper v. Metropolitan Life Insurance Co." on Justia Law

Posted in: ERISA

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3M filed an insurance claim to recover losses incurred on a number of investments due to fraud perpetrated by its own investment advisors. The Eighth Circuit affirmed the district court's grant of summary judgment to the Insurers, holding that the ownership requirement of Endorsement 8 applies to the Employee Dishonesty provision. Therefore, 3M does not own the stolen earnings and cannot seek coverage for the earnings under the Policy. Until the earnings were distributed to the partners, the stolen earnings were property of WG Trading, not 3M. The court explained that it is fundamental that property acquired with partnership funds is partnership property, and individual partners do not own partnership assets until the winding up of the partnership. Finally, the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., does not alter general commercial property rights, but merely defines the nature and scope of the fiduciary duties owed to plan participants. View "3M v. National Union Fire Insurance" on Justia Law