Articles Posted in ERISA

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Plaintiff, a former employee of Semi, filed a derivative lawsuit on behalf of a defined-contribution retirement savings plan and, in the alternative, as a putative class action on behalf of plan participants, claiming that Semi and others breached their fiduciary duties under the Employee Retirement Income Security Act (ERISA). The Eighth Circuit affirmed the district court's dismissal of the complaint for failure to state a claim and held that, under Fifth Third Bancorp v. Dudenhoeffer, 573 U.S. 409 (2014), plaintiff's allegations were insufficient to plausibly state a claim for breach of the duty of prudence. Finally, the court affirmed the denial of plaintiff's motion for leave to amend his complaint because he failed to submit a proposed amended complaint with his motion. View "Usenko v. MEMC LLC" on Justia Law

Posted in: ERISA

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Former employees of Honeywell, who retired before age 65 during the terms of Honeywell's 2007 and 2010 collective bargaining agreements (CBAs), filed a class action alleging that Honeywell's announced plan to terminate early retiree healthcare benefits at the end of 2017 breached the CBAs and violated the Employee Retirement Income Security Act of 1974 (ERISA), because those healthcare benefits vested when each class member retired. The Eighth Circuit agreed with the Sixth Circuit and held that the Supreme Court's decision in CNH Indus. N.V. v. Reese, 138 S. Ct. 761 (2018), was controlling in this case. Under Reese, the court held that plaintiffs' retiree healthcare benefits were not vested as a matter of law. Therefore, the court reversed and remanded for further proceedings. View "Pacheco v. Honeywell International Inc." on Justia Law

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The Eighth Circuit affirmed the district court's grant of ex-wife's motion to dismiss an action brought by ex-husband, alleging violations of the anti-alienation provisions of the Employee Retirement Income Security Act of 1974 (ERISA), that arose from payments he made to her for almost three decades. The court held that a prior state court judgment was entitled to res judicata effect where ex-husband had an opportunity to litigate the question of whether the state court had jurisdiction to address his violations of ERISA claims. View "Schwartz v. Bogen" on Justia Law

Posted in: Civil Procedure, ERISA

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In these consolidated cases, out-of-network medical providers who United intentionally failed to fully pay for services rendered to United plan beneficiaries in order to offset overpayments to the same providers from other United administered plans filed a class action under the Employee Retirement Income Security Act (ERISA) on behalf of their patients, the plan beneficiaries. Providers claimed that the relevant claim plan documents did not authorize United to engage in cross-plan offsetting. The Eighth Circuit affirmed the district court's grant of partial summary judgment to providers on the issue of liability and held that nothing in the plan documents even comes close to authorizing cross-plan offsetting. Furthermore, the practice of cross-plan offsetting was in some tension with the requirements of ERISA. While the court need not decide whether cross-plan offsetting necessarily violated ERISA, the court held that United's interpretation of the documents was not reasonable. View "Louis J. Peterson, D.C. v. UnitedHealth Group Inc." on Justia Law

Posted in: ERISA

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The Eighth Circuit affirmed the district court's grant of summary judgment for Proctor and Gamble in an action brought by an employee under the Employee Retirement Income Security Act (ERISA) after his disability benefits were terminated. The court held that plaintiff possessed the information necessary to litigate his claim and was thus not prejudiced by any procedural irregularities; the company did not abuse its discretion in denying plaintiff's claim for benefits where the denial letter adequately stated the reasons for supporting its decision; and the company's interpretation of the plan was reasonable and there was substantial evidence to support its decision. The court held that plaintiff's remaining claims were unavailing and the district court did not abuse its discretion by denying plaintiff's request for statutory penalties. View "Leirer v. Procter & Gamble Disability Benefit Plan" on Justia Law

Posted in: ERISA

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The Eighth Circuit reversed the district court's judgment against Liberty Life in an action filed by plaintiff under the Employee Retirement Income Security Act (ERISA), alleging that the company's denial of long-term disability benefits under his employer's welfare plan was an abuse of discretion. The court held that Liberty Life's decision was not an abuse of discretion because the medical opinions the district court rejected were supported by medical evidence and were sufficiently reliable to provide a reasonable basis for defendant to deny the claim. The court also vacated the award of attorney's fees. View "Zaeske v. Liberty Life Assurance Company of Boston" on Justia Law

Posted in: ERISA

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Plaintiffs filed suit against Anderson Excavating under 29 U.S.C. 185(a), 29 U.S.C. 1132, and 29 U.S.C. 1145, requesting that the district court order Anderson Excavating to pay the contributions it allegedly owed to the Welfare Plan and Pension Plan, along with interest, liquidated damages, and attorneys' fees and costs. The Eighth Circuit held that the district court erred in determining damages for unpaid contributions, prejudgment interest, liquidated damages, and attorneys' fees; the district court legally erred in applying the alter ego doctrine to justify an award of unpaid contributions for an alleged employee's work; and thus the court reversed the judgment of the district court and remanded for further proceedings. View "Marshall v. Anderson Excavating & Wrecking" on Justia Law

Posted in: ERISA

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The Eighth Circuit affirmed the district court's dismissal of plaintiff's complaint for failure to state a claim. Plaintiff alleged that his former employer, Wells Fargo, breached their fiduciary duty under the Employment Retirement Income Security Act (ERISA). The court held that the district court correctly determined that plaintiff's omission of any meaningful benchmark in his complaint meant that he failed to allege any facts showing the Wells Fargo Target Date Funds were an imprudent choice. In this case, plaintiff did not plead that the Funds were underperforming and his conclusory allegations of bad conduct did not save the complaint from its deficient pleading. Therefore, plaintiff failed to state a claim for relief under ERISA. View "Meiners v. Wells Fargo & Co." on Justia Law

Posted in: ERISA

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Apple acquired the Rogers, Arkansas Applebee’s Neighborhood Grill & Bar, and offered its employees a benefits package that included Guardian life insurance. Megan Moore alleged that employee James Moore enrolled for “basic life coverage” equal to 150% of his $62,000 annual salary, and “voluntary term life coverage” equal to five times his salary ($310,000). Megan, his designated primary beneficiary, alleged that Apple withheld premiums for the voluntary coverage from Moore’s salary until he died in 2013, but “failed to pay over those premiums” and to forward Moore’s application to Guardian. Mehan filed a proof of claim with Guardian, which indicated that premiums had not been received. Megan sued, asserting state law claims for breach of contract, negligence, breach of fiduciary duty, and promissory estoppel and seeks actual and punitive damages. The Eighth Circuit affirmed the dismissal of the complaint. The Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a), preempted all of Moore’s claims. “Allowing state law claims premised on the existence of an ERISA plan to proceed against the plan administrator would affect relations between primary ERISA entities and impact the administration of the plan.” The court noted that Moore's Second Amended Complaint alleging claims under ERISA, 29 U.S.C. 1132(a)(1)(B) and (a)(3) for wrongful denial of plan benefits, breach of fiduciary duty, and equitable estoppel, remains pending. View "Moore v. Apple Central, LLC" on Justia Law

Posted in: ERISA

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Act 900, Arkansas Code Annotated 17-92-507, an amendment to the state's then-existing maximum allowable cost (MAC) law that governed the conduct of pharmacy benefits managers, was preempted by the Employee Retirement Income Security Act (ERISA) and Medicare Part D statutes. The Eighth Circuit affirmed the district court's ERISA ruling in this case, but reversed the Medicare Part D ruling. The court remanded for entry of judgment for PCMA. View "Pharmaceutical Care Management v. Rutledge" on Justia Law

Posted in: ERISA, Health Law