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Hampers
v. W. R. Grace & Co., Inc.,
202 F.3d 44 (1st Cir. 2000)
Jones
v. UNUM Life Insur. Co.,
2000 U.S. App. LEXIS 259 (2nd Cir. Jan. 11, 2000)
- Since the
district court had not
articulated any reason for denying attorneys' fees, it must remand the case to
the district court for appropriate and informative findings. In the absence of
findings to determine the proper interest rate, meaningful review was
forestalled, and a remand to the district court was necessary.
DiFederico v. Rolm Co., 201 F.3d 200 (3rd Cir. 2000) - DiFederico appealed the district court’s denial of relief under ERISA § 510, 29 U.S.C. § 1140, a provision that makes it unlawful to interfere with the attainment of rights or benefits associated with an employee benefit plan. This court affirmed the district court’s decision, first pointing out that the standard in § 510 cases requires the plaintiff to demonstrate that the defendant had the " 'specific intent' " to violate § 510—in other words, that "the employer made a conscious decision to interfere with the employee's attainment of pension eligibility or additional benefits." See detailed analysis.
Shores v. Lucent Technologies, Inc., 2000 U.S. App. LEXIS 455 (4th Cir. Jan. 13, 2000) (Unpublished)-The district court granted Lucent's motion for summary judgment on all counts and denied Appellants' partial motion for summary judgment. This court affirmed on the grounds that plaintiffs failed to establish the elements for interference with their rights under ERISA § 510. ERISA § 510 prevents an employer from "discharging ... a participant for the purpose of interfering with the attainment of any right to which such participant becomes entitled under the plan." 29 U.S.C. § 1140. See detailed analysis.
Booth v. Wal-Mart Stores, Inc., 201 F.3d 335 (4th Cir. 2000)-This case involves a suit for wrongful denial of benefits under 29 U.S.C. § 1132(a)(1)(B). The plan denied the claim based on the preexisting condition limitation. Rather than sort through the conflicting medical opinions, this court turned to the question of standard of review, and found that the Plan’s decision was principled and reasoned, and the evidence before it supported its conclusions. See detailed analysis.
Ehlmann v. Kaiser Foundation Health Plan of Texas, 198 F.3d 552 (5th Cir. 2000) - Kaiser had no duty to disclose its financial incentive or bonus arrangements between the HMO’s and their contracting physicians. See detailed analysis.
Walsh v. United Parcel Service, 201 F.3d 718 (6th Cir. 2000); 2000 FED App. 0007P (6th Cir.)-Walsh, a former management pilot for UPS, claimed that he was wrongly discharged in violation of § 510 of ERISA, 29 U.S.C. § 1140, after he went on disability leave in 1993 due to complications stemming from an earlier car accident. This court affirmed the district court’s grant of summary judgment in favor of UPS on all claims. The Court agreed that plaintiff had failed to state a prima facie case. The court found that plaintiff had produced no evidence showing it was defendant's specific intent to fire plaintiff to prevent him from receiving long-term disability benefits. Further, the court found that even if the plaintiff did present a prima facie case, UPS had articulated a reasonable non-discriminatory grounds for terminating plaintiff--his failure to provide medical information concerning his eligibility for continued leave. See detailed analysis.
Howard v. Cyprus Amax Minerals Benefits Committee, 2000 U.S. App. LEXIS 632 (6th Cir. Jan. 13, 2000) (Unpublished).-After sustaining a back injury at work, Howard sought total disability benefits from his employer’s Plan. The 1992 Plan required that to be "totally disabled" a participant must have "unavoidable bodily injury or disease so as to be prevented from performing any type of work for the Company," and that disability must be permanent. Here, Howard had returned to work for two short periods of time between the injury and the eventual denial of benefits. The Plan Committee decided that his returns to work defeated his claim of total disability and denied the claim. He appealed the district court's grant of summary judgment in favor of the Committee on his claim under 29 U.S.C. § 1132(a)(1)(B). This court affirmed after concluding that the district court properly determined that the Committee's decision was not arbitrary or capricious. See detailed analysis.
McGuire v. Reliance Standard Life Insur. Co. 2000 U.S. App. LEXIS 786 (6th Cir. Jan. 18, 2000) (Unpublished).-At issue in this case was language in a life insurance policy that excluded coverage for "any loss ... to which sickness or disease is a contributing factor." This court affirmed denial of benefits on the grounds that the evidence upon which Reliance relied—the police report, the death certificate, the autopsy reports, prior medical records, and a peer review evaluation of the cause of death—did show that Mr. Wallace’s arteriosclerotic cardiovascular disease was a contributing cause of his drowning death. See detailed analysis.
Laborers Health and Welfare Trust Fund for Northern California v. Leslie G. Delbon Co. Inc., 199 F.3d 1109 (9th Cir. 2000). The Ninth Circuit addressed when an employer may no longer be obligated to pay into a fund. This court affirmed the district court’s holding that after 1984, Delbon had no obligation to make contributions to the Fund. See detailed analysis.
Kuchta
v. The General Dynamics Retirement Plan,
2000 U.S. App. LEXIS 512 (9th Cir. Jan. 11, 2000)(Unpublished).
Cline v. The Industrial Maintenance Engineering & Contracting Co., 200 F.3d 1223 (9th Cir. 2000).-ERISA does not cover plans at issue since such plans were IRA's. See detailed analysis.
Rutledge v. Seyfarth, Shaw, Fairweather, & Geraldson, 210 F.3d 1212 (9th Cir. 2000).ERISA preempts state law claims that attorneys charged excess legal fees to plans. See detailed analysis.
Corral v. Southern California Gas Company, 2000 U.S. App. LEXIS 925 (9th Cir. Jan. 21, 2000)(Unpublished).-This court affirmed the district court’s summary judgment in favor of Southern California Gas Co., holding as a matter of law that (1) SCGC was not seriously considering the ERIP when Corral elected to retire and therefore did not have to inform Corral of the program, and (2) the three-year statute of limitations served as a bar since there was no fraud or concealment. See detailed analysis.
Inter-Modal Rail Employees Ass’n. v. Burlington Northern and Santa Fe Railway Co., 2000 U.S. App. LEXIS 963 (9th Cir. Jan. 21, 2000)(Unpublished).-No error in retroactively applying one-year statute of limitation in claim under 29 U.S.C. § 1140.
Wolf v. Coca-Cola Co., 200 F.3d 1337 (11th Cir. 2000).-Wolf’s claim for benefits under ERISA failed because Wolf failed to meet the two requirements necessary to be considered a plan participant. See detailed analysis.
