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Harris v. Harvard Pilgrim Health Care Inc., 208 F.3d 274 (1st Cir. 2000)-This appeal concerned a subrogation agreement. Under the agreement, plan members Michael and Wendy Harris had to reimburse the plan money recovered in a tort action against a third party. One issue was whether a plan could seek full reimbursement for amounts recovered, or only the amount minus the plan members' attorneys' fees in pursuing the tort action. This court noted "among the courts of appeals which have considered it, the majority view is that an ERISA plan need not contribute to attorney fees where its plain language gives it an unqualified right to reimbursement." This court followed these precedents, and vacated the district court's order directing HPHC to defray a pro rata share of the Harrises' attorney fees. See detailed analysis.
Owen v. Soundview 401(K) And Profit Sharing Plan, 2000 U.S. App. LEXIS 4321 (2nd Cir. Mar. 17, 2000) (unpublished)-This court concluded that the prohibited transaction rules were not before it on this appeal. See detailed analysis.
Wood v. Prudential Insur. Co. of America, 207 F.3d 674 (3rd Cir. 2000)-This court found that ERISA completely preempts a state law claim of discriminatory termination to avoid paying benefits. See detailed analysis.
U.S. v. Helbling, 209 F.3d 226 (3rd Cir. 2000)-The government convicted Helbling of embezzling funds from an ERISA profit sharing plan. This court agreed with the lower court's reasoning that even if the plan was exempt from certain provisions of ERISA, 18 U.S.C. § 1027 and 18 U.S.C. § 664 would still apply because they do not require that the plan in question be subject to all of ERISA's various provisions. See detailed analysis.
Todish v. Cigna Corp., 206 F.3d 303 (3rd Cir. 2000)- Todish appealed to gain the benefit of a New Jersey statutory exception to the six-year statute of limitations (tolling for "insane" persons.) The district court dismissed her suit for long-term disability benefits as time-barred. Court of Appeals affirmed. See detailed analysis.
Smith v. Contini, 205 F.3d 597 (3rd Cir. 2000)-This appeal addressed the issue of reciprocal agreements to combine years of service for pension purposes. This court reversed the district court's finding that the Teamsters Local 641 Pension Fund's 15-year service requirement for pension benefits did not violate ERISA's maximum 10-year vesting requirement contained in 29 U.S.C. § 1053 (pre-1986 version.) See detailed analysis.
Adams v. Freedom Forge Corp., 204 F.3d 475 (3rd Cir. 2000)-Former employees of Freedom Forge Corp. sued alleging that the company breached its ERISA fiduciary duties. Freedom Forge allegedly induced them into early retirement with oral assurances that their health insurance benefits would continue essentially unmodified until death. The plaintiffs presented sufficient evidence of the company's statements that would cause "a substantial likelihood" of "misleading a reasonable employee in making an adequately informed retirement decision." ERISA plan administrators have an independent fiduciary obligation "not to misinform employees through material misrepresentations and incomplete, inconsistent, or contradictory disclosures. See detailed analysis.
Stokes v. Westinghouse Savannah River Company, 206 F.3d 420 (4th Cir. 2000)-Stokes asserted that the plan illegally denied him a severance benefit. He alleged that a certain coordinating arrangement between WEC and Westinghouse Savannah (a wholly owned subsidiary)—through which Westinghouse Savannah transferred to WEC the payments that the Department of Energy paid it as reimbursement for severance benefits -- violated 29 U.S.C. § 1106(a)(1) (prohibiting a plan administrator or a plan fiduciary from transferring to or for the benefit of a party in interest any assets of the plan.) This court found that Stokes' ERISA argument failed for several reasons. See detailed analysis.
Whittaker v. Bellsouth Communications Inc. Career Alternative Plan for Management Employees, 206 F 3d. 532 (5th Cir. 2000)-Whittaker claimed that his former employer wrongly denied him benefits from the Career Alternative Plan ("CAP"). During the pending of the request for CAP benefits, Whittaker accepted benefits from defendant’s Discretionary Termination Allowance Plan ("DTAP"). The DTAP contained an agreement to waive, discharge, and release all claims against BST. This court upheld that release. See detailed analysis.
Jordan v. Michigan Conference of Teamsters Welfare Fund, 207 F.3d 854 (6th Cir. 2000); 2000 FED App. 0105P (6th Cir.)-This opinion addressed whether the "prohibited transaction" provision contained in 29 U.S.C. § 1106(a)(1) would prohibit a class of plaintiffs (fund participants) from remitting their attorneys' fee award pursuant to a settlement agreement to an alleged "party in interest." This court found no evidence of a "prohibited transaction." See detailed analysis.
Trustees for Michigan Carpenters Council Pension Fund v. W.W.A. Inc., 2000 U.S. App. LEXIS 6416 (6th Cir. Mar. 23, 2000) (unpublished)-The district court found, that in relation to alleged delinquent pension benefits, the WWA was current in its contributions as of August 28, 1998. This court declined to require a showing of irreparable harm in all cases, but otherwise summarily affirmed the district court's decision for no abuse of discretion. See detailed analysis.
Anderson v. Trumbull-Mahoning Medical Group, Inc., 2000 U.S. App. LEXIS 5482 (6th Cir. Mar. 22, 2000) (unpublished)-The issue was the timing of her disability. This court affirmed the district court's decision that Anderson did not suffer a "loss" under the terms of the policy until the time at which she was unable to work—not the time when she first noticed her sickness. See detailed analysis.
Brown-Graves Co. v. Central States, Southeast and Southwest Areas Pension Fund, 206 F.3d 680 (6th Cir. 2000); 2000 FED App. 0097P (6th Cir.)-The issue for this court was whether to give the term "casual drivers" its plain meaning, since the CBA did not define it, or to allow Brown-Graves in effect to supply the meaning. After evaluating conflicting holdings in the 7th and 8th Circuits, this court placed special importance on the fact that Central States had no notice of Brown-Graves' unusual use of the term "casual." See detailed analysis.
Wilson v. Ashland Hospital Corp., 2000 U.S. App. LEXIS 3565 (6th Cir. Mar. 3, 2000) (unpublished)-This court affirmed that Wilson failed to show the elements of an ERISA § 510 retaliatory termination. See detailed analysis.
Health Care Service Corp. v. Brown & Williamson Tobacco Corp., 208 F.3d 579 (7th Cir. 2000)-Judge Easterbrook re-stated an earlier the finding that in the context of suits by health plans against tobacco companies; insurers may recover only to the extent they are subrogated to the rights of their insureds. See Teamsters Health and Welfare Trust Fund v. Philip Morris Inc., 196 F.3d 818 (7th Cir. 1999). See detailed analysis.
Parker v. AH&L, Inc., 2000 U.S. App. LEXIS 5040 (7th Cir. Mar. 23, 2000) (unpublished)-Considering only the issue of whether the magistrate judge properly denied Parker's requests for costs and attorney's fees under Federal Rule of Civil Procedure 54(d)(1) and 29 U.S.C. § 1132(g)(1), this court affirmed the judge's decision that neither Parker nor AH&L was a "prevailing party." See detailed analysis.
Trustmark Life Insur. Co. v. The University of Chicago Hospitals, 207 F.3d 876 (7th Cir. 2000)-Hospital succesfully pled a defense of promissory estoppel. See detailed analysis.
Shea v. Esensten, 208 F.3d 712 (8th Cir. 2000)- State law fraud and misrepresentation claims based on doctors' failure to disclose conflict of interest created by contractual incentives were not barred by ERISA; district court did not err in finding attempt to amend complaint to add defendant was untimely; in an appeal of a summary judgment, the record on appeal is limited to the evidentiary materials before the trial court, and portion of appendix containing additional materials not before court must be stricken. See detailed analysis.
Chicago Truck Drivers, Helpers and Warehouse Workers Union Pension Fund v. Brotherhood Labor Leasing Corp., 207 F.3d 500 (8th Cir. 2000)-In civil contempt action to enforce ERISA contributions judgment, the court erred in placing burden on Pension Fund to show defendants had ability to pay; the court also abused its discretion in making no express findings concerning whether corporate officer had committed acts which might support finding of contempt against him personally; case remanded for further proceedings. See detailed analysis.
Herring v. The Canada Life Assurance Company, 207 F.3d 1026 (8th Cir. 2000)-District court did not err in granting plaintiff's motion for summary judgment and awarding benefits; plaintiff's evidence clearly showed he was disabled under the provisions of the plan; treating physician's affidavit was properly considered in order to clarify and explain error in his deposition testimony. See detailed analysis.
Davolt
v. Executive Committee of O'Reilly Automotive,
206 F.3d 806 (8th Cir. 2000)
Sahulka v. Lucent Technologies, Inc., 206 F.3d 763 (8th Cir. 2000)-Plan's decision not to award discretionary death benefits was supported by substantial evidence. See detailed analysis.
Stewart v. Thorpe Holding Co., 207 F.3d 1143 (9th Cir. 2000)-This appeal concerned whether a marital dissolution order constituted a qualified domestic relations order (QDRO). This court chastised the district court for exalting form over substance. See detailed analysis.
Achtel v. Connecticut Mutual Life Insur. Co., 2000 U.S. App. LEXIS 5228 (9th Cir. Mar. 24, 2000) (unpublished)-In spite of de novo review, this court affirmed the district court's holding for Mass Mutual. Achtel's doctors' reports supported Mass Mutual's conclusion that Achtel's back disability was a pre-existing condition. See detailed analysis.
Simon v. Value Behavioral Health, Inc., 208 F.3d 1073 (9th Cir. 2000)-Court refused to extend the holding in Misic v. Building Serv. Employees Health & Welfare Trust, 789 F.2d 1374 (9th Cir. 1986) (per curiam) to assignees of health care providers. See detailed analysis.
In re Homer Lee Knight, 207 F.3d 1115 (9th Cir. 2000)-This case concerned whether a district court's lack of subject matter jurisdiction precluded it from awarding costs and attorneys' fees against a plaintiff alleging a cause of action under ERISA. This court concluded that lack of subject matter jurisdiction did preclude the court from awarding fees and costs under 29 U.S.C. § 1132(g)(1). See detailed analysis.
BankAmerica Pension Plan v. McMath, 206 F.3d 821 (9th Cir. 2000)-ERISA does not preempt the state law doctrine of substantial compliance. Since there was no preemption, this court applied California’s "substantial compliance" law, holding that the unsigned form did not substantially comply. In California cases, the courts have applied the doctrine to protect insureds from an insurer's bureaucratic negligence, not from their own failure. Here, the onus was on Mr. Montgomery to sign the form. See detailed analysis.
Bell v. Hawaiian Airlines, Inc., 2000 U.S. App. LEXIS 3674 (9th Cir. Mar. 8, 2000) (unpublished)-This court pointed out that "although it is true that '[a] demand for benefits is not a written request' for information, Moothart v. Bell, 21 F.3d 1499, 1503 (10th Cir. 1994), courts could reasonably interpret these two letters, viewed in context, as both requests for information and demands for benefits. Thus, summary judgment was improper. See detailed analysis.
Baizer v. Commissioner of Internal Revenue, 204 F.3d 1231 (9th Cir. 2000)-This appeal raised the issue of whether the Department of Treasury has the authority to impose tax penalties as a result of "prohibited transactions" with a qualified pension plan when the Department of Labor has entered into a consent judgment concerning the plan. This court found that the Department of Treasury does in fact possesses such authority under the enforcement provisions. See detailed analysis.
Young v. Washington Gas Light Co., 206 F.3d 1200 (D.C. Cir. 2000)-Young and other former supervisors or managers sued their former employer, Washington Gas Light Co., when, after their retirement, it offered a "voluntary separation incentive program" (the "Window Program"). The Window Program was a one-time opportunity to receive specified additional benefits for leaving the company. Young alleged that the company breached its fiduciary duties under ERISA by failing to disclose, before their retirement, that the company was considering implementation of the Window Program. (In fact, the company had explicitly denied to the employees that it was considering any type of new retirement incentive program.) Young asserted that a duty to disclose arose both under the original plan and, alternatively, under the new Window Program as an ERISA plan itself. Court affirmed the denial of both of these claims. See detailed analysis.
