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

This appeal arose from a dispute between Unum and the late Kevin Sullivan over long-term disability benefit payments. Sullivan sued Unum, arguing that the termination of his benefits violated the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., and Unum counterclaimed for overpayment of benefits. The court concluded that it was not an abuse of discretion for the administrator to determine that the large payments that Sullivan received in 2004 were payments for the sale of a business for the purpose of calculating his benefits. Unum asserted that the payments were salary, not income. The court reversed the district court's grant of summary judgment and award of attorney's fees, remanding for consideration of Unum's counterclaims. View "Sullivan v. Unum Life Ins. Co., et al" on Justia Law

Plaintiff, a former software developer for Lockheed Martin Corporation, brought this action for judicial review after Connecticut General terminated his disability benefits in 2007. The court held that the district court properly applied an abuse of discretion standard; on the record, it was not an abuse of discretion to terminate plaintiff's benefits; and the district court did not err in denying plaintiff an opportunity to depose the expert at issue. Accordingly, the court affirmed the judgment. View "Siegel v. Connecticut General Life Ins., et al" on Justia Law

The Funds brought this action to recover delinquent payments from Park-Mark under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001-1461. Park-Mark contended that it should not be liable for these delinquent payments because it mistakenly made significant overpayments that required a set-off and a refund. The court affirmed the district court's grant of summary judgment in favor of the Funds where the district court did not abuse its discretion by holding that its initial order granting summary judgment disposed of Park-Mark's claim for restitution and the district court properly granted summary judgment in favor of the Funds where equity did not favor a refund on the facts. View "Greater St. Louis Construction, et al v. Park-Mark, Inc." on Justia Law

Decedent, father of plaintiffs, died without naming a beneficiary of his Unum life insurance. Plaintiffs sued Unum, asserting a breach of the policy and an Employee Retirement Income Security Act, 29 U.S.C. 1002 et seq., violation. The district court concluded that they lacked standing and dismissed the suit. The court concluded that the estate's decision not to appeal precluded the children from having a reasonable or colorable claim to benefits. Because plaintiffs could not become entitled to benefits, the court held that the district court properly dismissed the case. View "A.J., et al v. UNUM, et al" on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and state law, alleging that defendant had retaliated against him after he raised complaints protected by those statutes. The district court granted summary judgment to defendant on the federal law claims and dismissed the state law claims without prejudice. The court concluded that plaintiff failed to make a prima facie case of retaliation under ERISA. Likewise, plaintiff failed to make a prima facie case of retaliation under the FLSA. At any rate, plaintiff failed to show a causal connection between his complaint about holiday meal time and his termination six months later. Accordingly, the court affirmed the judgment. View "Shrable v. Eaton Corp." on Justia Law

Defendant Goding was a beneficiary of an Employee Retirement Insurance Security Act (ERISA), 29 U.S.C. 1001 et seq., Plan administered by Drury. Goding sustained injuries in a slip and fall accident and received benefits from the Drury-administered Plan, as well as compensation through the settlement of a civil suit related to those injuries. Pursuant to a subrogation provision in the ERISA Plan, Drury attempted to secure reimbursement from Goding for the benefits it paid but was unable to do so after Goding declared bankruptcy. Drury then attempted to obtain that reimbursement from the firm that represented Goding. The court affirmed the district court's finding that Drury could not obtain such reimbursement because the firm had not agreed to the Plan's subrogation provision and consequently was not contractually bound by it; Drury could not maintain a suit against the firm in equity and could not bring a state cause of action for conversion against the firm; and the firm should be awarded attorneys' fees for successful defense of a subsequent motion. View "Treasurer, Trustees of Drury Ind. v. Goding, et al." on Justia Law

Eloise Walker, mother of the decedent, appealed the grant of summary judgment in favor of Pamela Wright-Dallas, the named beneficiary under the decedent's benefits plans. Walker argued that the district court erred because it made a ruling without first reviewing the entire administrative record, and in the alternative, the district court erred by applying the wrong standard of review. The court found no plain error and rejected Walker's claim that the district considered an inadequate record; the district court properly applied the abuse-of-discretion standard; and a heightened standard of review was not warranted. Accordingly, the court affirmed the judgment. View "Trustees of the Local No. 1, et al. v. Walker" on Justia Law

The United Automobile, Aerospace, and Agricultural Implement Workers International Union and Local 997 appealed the district court judgment after a five-day bench trial declaring that Whirlpool Corporation may unilaterally modify the health care benefits it provided to retired hourly workers previously employed at the Newton, Iowa manufacturing facilities of Whirlpool's now-dissolved subsidiary, Maytag Corporation. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court correctly found that a case or controversy existed when Whirlpool filed its declaratory judgment action; and (2) the retirees did not have a vested right to the previously granted health benefits under ERISA, as the benefits were provided in a collectively bargained agreement that had no express vesting provision. View "Maytag Corp. v. Int'l Union" on Justia Law

Aetna Life Insurance Company, as the plan administrator, determined Sharon Wade was no longer disabled and stopped paying long-term disability benefits from Wade's former employer's welfare benefit plan. Wade sought judicial review of Aetna's decision by filing a civil action under ERISA. The district court granted summary judgment in favor of Aetna, concluding that Aetna did not abuse its discretion in terminating Wade's benefits because substantial evidence supported the decision. The Eighth Circuit Court of Appeals affirmed, holding that the district court (1) applied the appropriate standard of review; (2) gave appropriate weight to the Social Security Administration's grant of long-term disability benefits to Wade; and (3) did not abuse its discretion by determining substantial evidence supported Aetna's termination of benefits. View "Wade v. Aetna Life Ins. Co." on Justia Law

LINA appealed the district court's ruling that LINA abused its discretion in denying death benefits to Dawn McClelland based upon her husband's life insurance policy. LINA also appealed the district court's award of attorney's fees. The court found that LINA committed an abuse of discretion in denying benefits because its interpretation was contrary to the language of the plan that it would cover "loss of life" based upon an "accident" and because substantial evidence did not support its decision. The court also found that the total fee awarded should be $85,000 and remanded to the district court to enter an award in that amount. The prejudgment interest award was affirmed.