Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Plaintiff appealed the district court's entry of summary judgment in favor of Open Harvest on plaintiff's claim alleging a violation of section 510 of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1140. Because plaintiff has not identified direct evidence of a specific intent to interfere with her ERISA benefits, the court must analyze her claim under the McDonnell Douglas burden-shifting framework. In this case, Open Harvest articulated a legitimate, non-discriminatory justification for its failure to pay the August policy premium. Under the McDonnell Douglas framework, the burden shifted back to plaintiff to show a genuine dispute whether Open Harvest's justification was pretextual. Plaintiff failed to show a genuine dispute whether Open Harvest terminated her employment with a specific intent to interfere with her ERISA benefits. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Open Harvest. View "Barnhardt v. Open Harvest Cooperative" on Justia Law

Plaintiff, the surviving spouse of an Acxiom employee, filed suit for accidental death benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. On appeal, Unicare appealed the district court's grant of summary judgment in favor of plaintiff. The court held that the district court correctly applied an abuse-of-discretion standard of review; the district court correctly found that UniCare erred in denying coverage for accidental death benefits where all of the evidence indicated that the spouse's death was the unexpected result of ingested prescribed medications; the district court correctly found that UniCare had not proven that the exclusion should be used to deny coverage; and the fee award was reasonable. Accordingly, the court affirmed the judgment of the district court. View "Nichols v. Acxiom Corp." on Justia Law

Plaintiff appealed the district court's denial of her motion for judgment on the record, affirming Liberty's termination of long-term disability benefits and dismissal of the complaint with prejudice. The policy provided that an employee was not disabled if the employee was capable of performing any occupation for which he or she was reasonably fitted. The court concluded that Liberty did not abuse its discretion in determining that plaintiff was reasonably fitted to perform the occupation of ambulance/emergency service dispatcher. Therefore, the record reflected that Liberty's decision to terminate benefits was supported by substantial evidence and thus did not constitute an abuse of discretion. Accordingly, the court affirmed the judgment of the district court. View "Gerhardt v. Liberty Life Assurance Co., et al." on Justia Law

Plaintiffs filed suit against their former employer and others under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. After the district court adopted the magistrate judge's recommended dispositions, plaintiffs appealed. The court concluded that plaintiffs have failed to set forth sufficient evidence to show that they were due more in benefits and penalties than the amount that the district court determined that they were owed; the district court did not abuse its discretion in denying their requests for nonmonetary relief or in determining the reasonable attorney's fees and costs; and, therefore, the court affirmed the judgment of the district court. View "McDowell, et al. v. Price, et al." on Justia Law

Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001-1461, alleging that defendants violated ERISA when defendants, realizing that they had paid plaintiffs excess retirement benefits, reduced plaintiffs' monthly benefit payments and recouped overpayments through withholding. The court concluded that Count One of the complaint was time-barred; the court rejected plaintiffs' argument that defendants had no authority to either correct or recoup the benefit overpayments where the 2002 plan booklet contained broad language granting defendants such action; because the PPNPF was a defined-benefit plan, plaintiffs could not recover individualized relief in a section 1132(a)(2) claim; and plaintiffs' claim for equitable estoppel under section 1132(a)(3)(B) failed where this claim mirrored Count One's section 1132(a)(1)(B) claim. Accordingly, the court affirmed the district court's grant of summary judgment for defendants. View "Pilger, et al. v. Sweeney, et al." on Justia Law

Parents appealed from the district court's grant of summary judgment in favor of defendant, arguing that the district court erred in concluding that the antenuptial agreement between their son and his then-wife, Kathy L. Cox, was ineffective to waive Kathy's right to the funds in Michael's 401(k) plan. The son died before his divorce from Kathy was finalized. The parties agreed that the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., governed the distribution of the funds in the plan. The court concluded that the son's designation of his Parents as beneficiaries of the plan must yield to Kathy's rights as a surviving spouse, agreeing with the district court that Kathy's consent did not satisfy the acknowledgment requirement of section 1055(c)(2)(A)(iii). View "MidAmerican v. Cox, Sr., et al." on Justia Law

DM&E and its president and CEO, defendant, entered into an Employment Agreement to encourage his retention following an anticipated change of control. When DM&E terminated defendant without cause and triggered the Employment Agreement's severance provision, defendant filed a demand for arbitration under the Employment Agreement. DM&E then filed this action in federal court to enjoin the arbitration. The court agreed with the district court that the benefits sought in defendant's arbitration demand were not claims for benefits due under an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., plan. The court held that it lacked federal subject matter jurisdiction to consider arbitrability, or any other issue arising under the Employment Agreement. View "Dakota, MN & Eastern R.R. v. Schieffer" on Justia Law

Plaintiff, as trustee of the Plan, brought this action against Principal, alleging violations of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. At issue was whether the district court abused its discretion in refusing to certify a class. The court held that the Confidential Agreement and consent judgment in this case permitted plaintiff to revive his individual claim in order to petition the district court for additional recovery and therefore, the district court's decision was not final. Further, plaintiff's voluntary dismissal of his individual claims rendered the case moot where plaintiff has relinquished his claims and there was no longer an Article III case or controversy. Accordingly, the court lacked jurisdiction and dismissed the appeal. View "Ruppert v. Principal Life Ins. Co." on Justia Law

Plaintiff brought this action under 29 U.S.C. 1132(a)(1)(B) claiming that Hartford wrongfully terminated her long-term disability benefits under an employee welfare benefit plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001-1461. The court affirmed the judgment of the district court granting summary judgment in favor of Hartford where plaintiff failed to exhaust her administrative remedies by failing to file a timely administrative appeal. The letter at issue could have reasonably been construed by Hartford as a request for documents rather than a request for an appeal. View "Reindl v. Hartford Life and Accident Ins." on Justia Law

Hostess provided an "employee welfare benefit plan" under the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1002(1). In this appeal, appellant challenged the order of the district court affirming the grant of summary judgment by the bankruptcy court in favor of Hostess on his claim for civil penalties for Hostess's failure to give notice of certain health insurance coverage rights required under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA), 29 U.S.C. 1166(a), and the denial of attorney's fees. Although it was undisputed that Hostess failed to provide two notices required by COBRA, the court rejected appellant's arguments and held that the bankruptcy court did not err in granting summary judgment to Hostess on his claim for civil penalties. The court agreed with the bankruptcy court that it could not "fairly call the outcome of the litigation some success on the merits" as required to award attorney's fees and costs to appellant. View "Deckard v. Interstate Bakeries Corp., et al" on Justia Law