Case Summaries

ERISA

[09/08] Murphy v. Deloitte & Touche Grp. Ins. Plan
In an action concerning defendant's denial of disability benefits under an ERISA plan, summary judgment for defendant is vacated where: 1) the court's case law prohibited courts from considering materials outside the administrative record where the extra-record materials sought to be introduced related to a claimant's eligibility for benefits; and 2) neither a claimant nor an administrator should be allowed to use discovery to engage in unnecessarily broad discovery that slows the efficient resolution of an ERISA claim.

[09/07] Alday v. Raytheon Co.
In an action alleging that defendant breached collective bargaining agreements (CBAs) with plaintiffs and violated the Labor Management Relations Act (LMRA) and the Employee Retirement Income Security Act (ERISA), summary judgment for plaintiffs is affirmed where: 1) the language of the CBAs made clear that defendant's agreement to pay retiree medical insurance premiums continued beyond the term of the CBAs, even where its agreement to pay non-retired employee premiums did not; 2) defendant's leeway to amend its benefit plans did not allow it to alter the terms of the CBAs under which it agreed to provide company-paid health insurance to retirees; and 3) plaintiffs failed to allege sufficient facts supporting their claim for punitive and extra-contractual damages.

[08/31] Cent. States Southeast & Southwest Areas Pension Fund v. O'Neil Bros. Transfer & Storage Co.
In a multi-employer pension fund administrator's suit against an employer seeking interim payment of withdrawal liability under the Employee Retirement Income Security Act, district court's grant of summary judgment for administrator is affirmed as defendant's default is governed by the provisions of 29 U.S.C. section 1399(c)(5)(B), and under that section, as interpreted reasonably by the Pension Benefit Guaranty Corporation (PBGC), the entire amount of the withdrawal payment is immediately payable upon default and that obligation is not deferred because of the pendency of arbitration.

[08/31] Howley v. Mellon Fin. Corp.
In plaintiff's suit for benefits and for unlawful discrimination under ERISA, as well as several related state law claims, arising from denial of plaintiff's claim for benefits under defendant's Displacement Program, district court's grant of plaintiff's motion for summary judgment is affirmed as, although the district court erred in applying a heightened standard of review and by considering the extra-record evidence that managers helped plan plaintiff's termination prior to the sale of the company, it is nonetheless clear that defendant abused its discretion in denying plaintiff's claim for benefits.

[08/30] Bell v. Pfizer, Inc.
In an action for failure to provide ERISA benefits, judgment for defendants is affirmed where defendants' alleged misrepresentations concerned only plaintiff's stock benefits under a non-ERISA plan and, therefore, did not violate any fiduciary obligations under ERISA.

[08/17] Marshall v. Baggett
In an action to recover delinquent contributions to an ERISA plan, judgment for plaintiff is vacated where the district court erred in granting the default judgment because the complaint did not support a judgment against defendant in her individual capacity.

[08/12] Gastronomical Workers Union Local 610 v. Dorado Beach Hotel Corp.
In a suit brought by the trustees of a multi-employer pension fund against employers under 29 U.S.C. section 1132(a)(3), which supplies a cause of action in favor of an ERISA fiduciary, claiming that employers failed to make sufficient payments to keep the Fund in compliance with ERISA's minimum funding requirement for 2005, judgment of the district court is affirmed in part, vacated in part and remanded where: 1) district court's dollar-certain judgment is vacated as, the record states that, by the time the court entered the judgment, the deficiency may have vanished, and the record contains no explanation of the vanishing deficiency sufficient to salvage the judgment; 2) district court did not err in denying remediation under section 502(g)(2); and 3) district court's order denying relief under section 502(g)(1) is vacated in light of the Supreme Court's decision in Hardt, and remanded for the district court to determine whether the trustees have achieved some degree of success on the merits, and decide whether to award attorneys' fees, costs, and/or other remedies encompassed within section 502(g)(1).

[08/10] Young v. Verizon's Bell Atlantic Cash Balance Plan
In plaintiff's class action suit under ERISA section 502(a) and U.S.C. section 1132(a) against Verizon and its Cash Balance Plan, claiming that defendant made two errors in calculating her opening cash balance, and hence her ultimate pension benefit under the plan, district court's grant of defendant's equitable reformation of its plan to correct a scrivener's error is affirmed as, although ERISA's rules for written plans are strictly enforced, they are not so strict as to prevent equitable reformation of a plan that is shown, by clear and convincing evidence, to contain a scrivener's error that is inconsistent with participants' expected benefits.

[08/10] Khoury v. Group Health Plan, Inc.
In an action disputing defendant-insurer's award of residual disability benefits to which plaintiff was entitled, summary judgment for defendant is affirmed where: 1) the district court did not err in finding the appeals committee had before it the very same information that plaintiff contended that defendant intentionally hid; 2) the district court properly considered the existence of a conflict of interest; and 3) the district court did not err in finding defendant's interpretation of the relevant contract provisions was reasonable.

[08/09] Jones v. ReliaStar Life Ins. Co.
In an action claiming that defendant insurer began offsetting the disability benefits plaintiff received under an ERISA plan by the amount of disability benefits he collected from the Department of Veterans Affairs, summary judgment for defendant is affirmed where the district court's decision involved an application of policy language to undisputed facts, and the administrative record was sufficient to permit a fair evaluation of defendant's decision, and thus the district court did not abuse its discretion in denying plaintiff's request for discovery.

[08/04] Holmstrom v. Metro. Life Ins. Co.
In plaintiff's ERISA action against Metropolitan Life Insurance Company (MetLife) for termination of her long-term disability benefits, district court's grant of summary judgment for MetLife on plaintiff's claim for benefits and MetLife's counterclaim to obtain a setoff for Social Security payments plaintiff received, is reversed and remanded where: 1) plaintiff has shown several other reasons for finding that MetLife acted arbitrarily and capriciously in terminating her benefits and then sticking with that decision through the administrative reviews for which plaintiff provided exactly the sort of detailed information that MetLife had demanded; 2) plaintiff's long-term benefits must be reinstated retroactively as of August 5, 2005; and 3) the district court must have an opportunity to consider plaintiff's request for attorney fees and prejudgment interest on remand.

[07/30] Walker v. Monsanto Co. Pension Plan
In a class action lawsuit challenging the manner in which certain credits accrue in the defendant company's pension plan as inconsistent with a provision of the Employee Retirement Income Security Act (ERISA), district court's grant of defendant's motion for summary judgment is affirmed as the interest credits have no impact on the accrued benefit at normal retirement age and therefore have no effect on an employee's rate of benefit accrual, and Notice 96-8 and Revenue Ruling 2008-7 are wholly irrelevant to plaintiffs' claims.

[07/28] Rote v. Titan Tire Corp.
In an ERISA action challenging defendant-employer's denial of long-term disability benefits, judgment for plaintiff is affirmed where the treating doctors' affirmative responses, when read in context, showed that the restrictions on plaintiff's working capacity were permanent, not temporary. Moreover, the district court's attorney's fee award is affirmed where defendant relied on a hypertechnical reading of the medical evidence and ignored the doctors' attempts to clarify their opinions.

[07/26] Mitchell v. CB Richard Ellis Long Term Disability Plan
In an action seeking long-term disability benefits and attorneys' fees under the Employee Retirement Income Security Act (ERISA), judgment for plaintiff is affirmed where: 1) the district court correctly held that plaintiff was eligible for benefits under defendant's policy, and 2) defendant failed to cross-claim for indemnification from a third party in the district court action.

[07/22] Mack v. Kuckenmeister
In an action in federal court seeking to interplead $500,000 in retirement pension funds formerly owned by a murder victim, the dismissal of the action is reversed where state courts had subject matter jurisdiction to decide that a state court issued domestic relations order was a Qualified Domestic Relations Order, as defined by the Employee Retirement Income Security Act.

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