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Orvosh v. Program Of Group Insurance For Salaried Employees Of Volkswagen Of America, Inc., 222 F.3d 123 (3rd Cir. 2000)-This court reversed the district court's finding that Volkswagen was arbitrary and capricious in discontinuing Orvosh's long-term disability benefits. Although there were conflicting doctor's opinions on Orvosh's level of disability, the evidence showed there were jobs which he could perform and for which he was "reasonably fitted by education, training, or experience." See detailed analysis.
Bigelow v.. United Healthcare of Mississippi, Inc.., 213 F.3d 254 (5th Cir. 2000)-Plaintiff has no claim for equitable relief following inadvertent extension of plaintiff's COBRA (PHSA) coverage.
Corporate Health Insur., Inc. v. Texas Department of Insurance, 220 F.3d 641 (5th Cir. 2000)-In the wake of Texas' recent litigation concerning HMO liability for treatment decisions, this court denied Texas' petition for a rehearing en banc. See detailed analysis.
Sparks v. Unum Life Insur. Co., 2000 U.S. App. LEXIS 18169 (6th Cir. Jul. 21, 2000)(Unpublished)-Plan language requiring that a claimant show "proof" of disability (rather than "satisfactory proof," or "some other qualitative threshold of proof") does not grant discretion in a plan administrator. See detailed analysis.
Capriccioso v. Henry Ford Health Systems, 2000 U.S. App. LEXIS 17535 (6th Cir. Jul. 17, 2000)(Unpublished)-This court affirmed the district court's summary judgment that HFHS's salary continuation policy was not an employee welfare benefit plan under ERISA. See detailed analysis.
NGS
American, Inc. v. Jefferson, 218 F.3d 519 (6th Cir. 2000); 2000 FED
App. 0216P (6th Cir.)-In
response to Jefferson's suit for wrongful death and medical malpractice in
influencing the health care providers' treatment of his wife, NGS American, a
third-party health plan administrator, filed suit against Jefferson in a
Michigan (rather than Florida) federal court, seeking a declaratory judgment
that ERISA would preempt Jefferson’s state-court claims.
Ameritech Benefit Plan Committee v. Communication Workers of America, 220 F.3d 814 (7th Cir. 2000)-Plaintiff's section 510 retaliation failed because "section 510 only applies if the employees can show (among other things) that they qualified under the plan for the denied benefits." See detailed analysis.
Central States, Southeast and Southwest Areas Pension Fund v. Carstensen Freight Lines, Inc., 2000 U.S. App. LEXIS 16212 (7th Cir. July 10, 2000) (Unpublished)-This court affirmed the district court's summary judgment in favor of Central States, on the grounds that Carstensen failed to request timely arbitration, "as is ordinarily mandatory in multiemployer plan disputes," 29 U.S.C. § 1401(a)(1). See detailed analysis.
Schatz v. Mutual of Omaha Ins. Co., 220 F.3d 944 (8th Cir. 2000)-Decision to deny benefits was not entitled to sliding scale, less deferential standard of review for even though there was a conflict of interest in defendant's dual role as plan administrator and insurer, plaintiff failed to show this conflict actually caused the plan to breach its fiduciary duty to her; plan did not abuse its discretion in denying claim for benefits. See detailed analysis.
Wetzel v. Lou Ehlers Cadillac Group Long Term Disability Insurance Program, 222 F.3d 643 (9th Cir. 2000)-In dealing with statues of limitations in ERISA actions, this court overruled a prior key decision, Nikaido v. Centennial Life Ins. Co. 42 F.3d 557 (9th Cir. 1994), which had established the "rolling accrual" rule. See detailed analysis.
Prasad v. Connecticut General Life Insur. Co., 2000 U.S. App. LEXIS 18153 (9th Cir. Jul. 24, 2000)(Unpublished)-This court affirmed the district court's summary judgment against Prasad in his claim for long-term disability benefits. See detailed analysis.
Moser v. Trans-General Life & Casualty Group, 2000 U.S. App. LEXIS 18154 (9th Cir. Jul. 24, 2000)(Unpublished)-This court reversed the district court's sua sponte summary judgment against Moser on her claim for long-term disability benefits. See detailed analysis.
In re McIntyre, 222 F.3d 655 (9th Cir. 2000)-ERISA's anti-alienation provision, 29 U.S.C. § 1056(d)(1), does not protect from the IRS a spouse's community property interest in pension benefits. See detailed analysis.
Wright v. Riveland, 219 F.3d 905 (9th Cir. 2000)-This court followed the lead of the Third and Tenth Circuits, which held that the anti-alienation provision prevents the giving of an interest in a plan benefit payment which "is, or may become, payable to the participant or beneficiary" and does not apply to benefits the plans have already distributed. See Guidry v. Sheet Metal Workers Int'l Assoc., 10 F.3d 700 (10th Cir. 1993), aff'd in part on reh'g en banc, 39 F.3d 1078 (1994). See detailed analysis.
Welsh v. Metropolitan Life Insur. Co., 2000 U.S. App. LEXIS 16172 (9th Cir. July 11, 2000) (Unpublished)-This court reversed the district court's grant of summary judgment against Welsh since MetLife abused its discretion when it denied his claim for long-term disability benefits. This court found that the plan administrator never properly evaluated Welsh's claim in light of the plan's definition of "disability." See detailed analysis.
Stuart v. UNUM Life Insur. Co., 217 F.3d 1145 (9th Cir. 2000)-This Court addressed whether a group insurance plan offered by an employer satisfied the "safe harbor" criteria which would render it an employee welfare benefit plan subject to ERISA—a critical question when ERISA preemption is at issue. The court concluded that the scheme must meet all four requirements of the safe harbor regulation for it to take effect. See detailed analysis.
Hamilton v. Allen-Bradley, 217 F.3d 1321 (11th Cir. 2000)-When Hamilton suspected that her inability to work due to carpal tunnel syndrome might entitle her to long-term disability benefits, she inquired with the human resources director at her company, as procedure required. Lee, the director, allegedly stated on several occasions that Hamilton did not qualify, refused to provide Hamilton with a claim form, and failed to inform Hamilton of the identity of the company's disability plan insurer (UNUM). This court reversed the district court, concluding that the human resources director (and therefore Allen-Bradley) did qualify as a plan administrator and fiduciary, and that Hamilton stated valid claims for breach of fiduciary duty. See detailed analysis.
