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

Ibson and her family were insured by UHS through a policy available to her to as a member of her law firm. Due to an error, UHS began informing Ibson’s medical providers that Ibson and her family no longer had insurance coverage. Although UHS eventually paid the claims it should have paid all along, Ibson sued, raising state law claims of breach of contract, negligence, and bad faith, and seeking punitive damages. UHS responded that Ibson’s claims were preempted by the Employee Retirement Income Security Act (ERISA) and barred by the policy’s three-year contractual limitations period. The district court agreed and entered summary. The Eighth Circuit reversed and remanded, agreeing that Ibson’s state law claims are preempted under ERISA, but rejecting entry of summary judgment on the basis of the three-year contractual limitations period. View "Ibson v. United Healthcare Servs., Inc." on Justia Law

Plaintiff filed suit against Reliance and the Plan, under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., claiming that Reliance abused its discretion in denying long-term disability benefits. The district court granted summary judgment to plaintiff. The court concluded that Reliance's interpretation of the Plan is reasonable. The loss-of-license provision states that the loss of a license for any reason is insufficient in and of itself to entitle a claim to benefits. In this case, plaintiff's diagnosis of diabetes mellitus was not enough by itself to justify benefits. Reliance's interpretation merely requires that the claimant show that the injury or sickness itself renders him unable to perform his occupation. Further, Reliance's determination that plaintiff was not totally disabled was supported by substantial evidence and its denial of benefits was reasonable. Accordingly, the court reversed the judgment of the district court.View "Hampton v. Reliance Standard Life Ins. Co." on Justia Law

Two trustees of the Fund filed suit under section 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. 185(a), and section 515 of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1145, to collect unpaid benefit contributions allegedly owed by Goebel. On appeal, the Trustees challenged the dismissal of the ERISA claim. The court read the Trust Agreement to unambiguously require that an employee is actually represented by the Union at the time the Fund claims delinquent contributions were owed on behalf of that employee. As it is undisputed that the Union did not "represent" the employees at the times in question, the Trustees failed to demonstrate the Fund was entitled to the contributions they seek under the terms of the Trust Agreement. Accordingly, the court affirmed the district court's grant of summary judgment to Goebel.View "Kern, et al. v. Goebel Fixture Co." on Justia Law

Plaintiff filed suit against his deceased son's employer and the insurer, MetLife, under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq, after plaintiff was denied benefits of the son's life insurance policy. The court reversed the district court's grant of summary judgment to defendants on plaintiff's section 1132(a)(1)(B) claim where there were outstanding questions of material fact regarding whether MetLife abused its discretion when it denied benefits because the plan did not define evidence of insurability; reversed the denial of plaintiff's motion to add a claim under section 1132(a)(3); and remanded to the district court so that plaintiff has a full opportunity to litigate both his ERISA claims. View "Silva v. Metropolitan Life Ins. Co., et al." on Justia Law

Plaintiff filed suit against Sun Life, alleging that Sun Life improperly denied him long-term disability benefits under a disability plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. The court concluded that it was reasonable for Sun Life to conclude that plaintiff's vitamin A supplements constituted a "medical treatment." The court held that Sun Life did not abuse its discretion in denying plaintiff's claim for benefits under the Plan, in light of an ordinary understanding of what constitutes a "medical treatment" and the purpose of the Pre-Existing Condition clause. Accordingly, the court reversed the district court's entry of summary judgment to plaintiff and remanded for entry of summary judgment to Sun Life. View "Kutten v. Sun Life Assurance Co." on Justia Law

Plaintiff filed suit against his former employer, Medtronic, alleging that the company improperly denied his claim for benefits under a long-term disability plan governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that the district court did not abuse its discretion by admitting Medtronic's supplemental evidence for the limited purpose of determining the proper standard of review. The Plan provided Medtronic with complete and total discretionary authority to interpret and administer its provisions and this language is sufficient to trigger a deferential abuse-of-discretion standard of review and plaintiff failed to establish a procedural irregularity that would alter this standard or weigh in the court's consideration under it. Under this standard, the court agreed with the district court that Medtronic did not abuse its discretion in denying plaintiff's claim for "any occupation" long-term disability benefits. Accordingly, the court affirmed the judgment of the district court. View "Waldoch v. Medtronic, Inc." on Justia Law

Windstream filed suit against defendant and other retirees who challenged company authority to modify retiree benefits unilaterally. The court concluded that there was no evidence indicating that Windstream was required to obtain retiree consent. The court also concluded that the benefits were not permanently vested. Accordingly, the court affirmed the judgment in favor of Windstream. View "Windstream Corporation,., et al. v. Lee, et al." on Justia Law

Plaintiff filed suit against MetLife, alleging that MetLife abused its discretion in denying her claim to receive the proceeds of her late husband's life insurance policy under an employee-benefit plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. On appeal, plaintiff challenged the district court's grant of summary judgment to MetLife. The court concluded based on the evidence - the 1991 form, the husband's will, and the November 2010 form - that MetLife did not abuse its discretion in determining that the husband's son, rather than plaintiff, was the beneficiary of the life insurance proceeds. Even assuming that the substantial-compliance doctrine was available to federal courts in the interpleader context, the court would not extend it to the circumstances presented here. Where an ERISA plan administrator is given discretion under the plan to determine eligibility for benefits, the doctrine does not deprive the administrator from requiring strict compliance with the terms of the plan. Accordingly, the court affirmed the judgment of the district court. View "Hall v. Metropolitan Life Ins., et al." on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)(B), claiming that Prudential wrongly denied him long term disability (LTD) benefits under a group policy sponsored by his former employer, Vertis. The court concluded that the district court correctly concluded that the plan language as confirmed by the Summary Plan Description explicitly granted Prudential discretion to interpret the plan and to determine eligibility for benefits. Prudential did not abuse its discretion in denying plaintiff long term disability benefits where Prudential provided plaintiff the required full and fair review before denying his first appeal. The court agreed with the district court that the subsequent medical evidence submitted with plaintiff's voluntary second appeal did not render Prudential's denial of his mandatory first appeal an abuse of discretion. Accordingly, the court denied plaintiff's motion to strike Prudential's separate appendix and Prudential's motion for leave to file a Sur-Reply Brief. View "Prezioso v. Prudential Ins. Co." on Justia Law

These consolidated appeals arose from a class action against ABB under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. The district court entered judgment against the ABB defendants and the Fidelity defendants for breaching their fiduciary duties in violation of sections 1104, 1106, and 1109. The court affirmed the district court's judgment and award against the ABB fiduciaries with respect to recordkeeping; vacated the judgment and award on the participants' investment selection where the district court erroneously substituted its own de novo interpretation of the Plan, and mapping claims where the claims were timely; reversed the judgment against Fidelity where the district court erred in finding that Fidelity breached its fiduciary duty of loyalty by paying the expenses on the float accounts and distributing the remaining float to the investment options; vacated the attorney fee award as to all defendants; and remanded for further proceedings. View "Tussey, et al. v. ABB, Inc., et al." on Justia Law