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Paciello v. Unum Life Insur. Co., 2000 U.S. App. LEXIS 11580 (2nd Cir. May 23, 2000) (unpublished)-This court affirmed the district court's denial of Paciello's petition for class certification on her claim that UNUM Life Insurance Company failed to comply with ERISA's regulations. See detailed analysis.
Bressmer v. Federal Express Corporation Long Term Disability Plan, 2000 U.S. App. LEXIS 11024 (2nd Cir. May 16, 2000) (unpublished)-This court affirmed the District Court's summary judgment against Bressmer's claim that Federal Express wrongfully terminated her long-term disability benefits in violation of 29 U.S.C. § 1132(a)(1)(B). See detailed analysis.
Lettrich v. J.C. Penney Co. Inc., 213 F.3d 765 (3rd Cir. 2000)- Plaintiff alleged that the company terminated a welfare plan without providing proper notice as ERISA requires. This court reversed and remanded on the ground there was a fact issue whether J.C. Penney had "actively concealed" the termination of the plan. Notwithstanding the general rule that plan amendments are valid in spite of inadequate notice, participants may recover the benefits under the plan before the amendment if they can demonstrate active concealment and detrimental reliance. See detailed analysis.
Courson v. Bert Bell NFL Player Retirement Plan, 214 F.3d 136 (3rd Cir. 2000)-Courson, a former NFL football player, appealed the district court's summary judgment in favor of the Retirement Board. The Retirement Board denied his request to increase his disability benefits. This court affirmed the district court's summary judgment in favor of the Retirement Board. See detailed analysis.
Pinto v. Reliance Standard Life Insur. Co., 214 F.3d 377 (3rd Cir. 2000)-The court clarified for the Third Circuit the issue of the standard of review where there is a conflict of interest on the part of the plan decision-maker. See detailed analysis.
Syed v. Hercules, Inc., 214 F.3d 155 (3rd Cir. 2000)-Syed filed suit against his former employer after it discontinued his long-term disability benefits after two years. Hercules discontinued the benefits based on a doctor's opinion that he could do "sedentary to light" work (and therefore no longer met the definition of "total disability"). Syed made four arguments on appeal. This court affirmed the denial of all arguments on appeal. See detailed analysis.
Harte v.
Bethlehem Steel Corp., 214 F.3d 446 (3rd Cir. 2000)-Harte
sued his former employer, Bethlehem Steel, after it terminated his service
nineteen days short of the fifteen years which would make Harte eligible for a
pension with greater benefits.
The Bethlehem Plan provided for a break in continuous service two years
after active employment ends due to layoff or a disability.
Service does not break if an employee leaves active employment due to a
"compensable disability incurred during course of employment."
Harte had been absent from work for two years, and was receiving
long-term disability benefits for his cardiac problems.
This court agreed that the Bethlehem Plan administrator had the authority to make the interpretation that he did and to effect the termination. However, it reversed and remanded the summary judgment. The court found that a fact finder could find for Harte on a claim of breach of fiduciary duty under 29 U.S.C. § 1104, as well as the "catch-all" provision of 29 U.S.C. § 1132(a)(3). See detailed analysis.
Holmes
v. Pension Plan of Bethlehem Steel Corp.
213 F.3d 124 (3rd Cir. 2000)-Holmes
and Hollyfield successfully prosecuted a civil action against the Bethlehem
Steel pension plan for interest on pension benefits.
The plan had delayed paying the benefits for a decade and a half.
Here, however, they argue that the District Court erred by:
"(1) awarding interest at the statutory rate rather than requiring
the Plan to disgorge the actual profits it earned on their delayed benefits; (2)
concluding that the doctrine of laches applied to limit the period for which
they could recover interest; (3) denying certification of their proposed
plaintiff classes; and (4) concluding that the legal memorandum they sought to
discover was entitled to work-product immunity."
This Court affirmed the ruling on 1 and 3, remanded on 2 and reversed the district court on point 4. See detailed analysis.
Palmer v. Prudential Insur. Co., 2000 U.S. App. LEXIS 11341 (4th Cir. May 12, 2000) (unpublished)-This court affirmed the summary judgment against Palmer's claim that the plan wrongfully terminated her long-term disability benefits after almost two years. See detailed analysis.
Riley v. Administrator of the Supersaver 401k Capital Accumulation Plan , 209 F.3d 780 (5th Cir. 2000)-Affirming the district court without comment, this court took the opportunity to expound on the necessity of courts to consider the five "Bowen factors" when considering a request for attorneys' fees under 29 U.S.C. § 1132(g). See detailed analysis.
Manning
v. Hayes, 212 F.3d 866 (5th Cir. 2000)-This
appeal concerns a dispute between the estate of a deceased ERISA plan
participant and the decedent's ex-wife over life insurance benefits.
This court affirmed the district court's summary judgment in favor of
Allison Hayes, the ex-wife and the named beneficiary of his life insurance
policy.
Dorn
v. Internat'l Brotherhood of Electric Workers,
211 F.3d 938 (5th Cir. 2000)-In
this appeal, the court addressed the differing rights of QDRO's (Qualified
Domestic Relations Orders) and QJSA's (Qualified Joint and Survivor Annuities).
It affirmed the dismissal of Janice Dorn's claim for continued payment of
pension benefits following the death of her ex-husband, Jack.
Ravencraft
v. Unum Life Insur. Co.,
212 F.3d 341
(6th Cir. 2000); 2000 FED App. 0163P (6th Cir.)
Maurer
v. Joy Technologies, Inc.,
212 F.3d 907 (6th Cir. 2000); 2000 FED App. 0166P (6th
Cir.)
Bucks v. Reliance Standard Life Insur., Co., 2000 U.S. App. LEXIS 11456 (6th Cir. May 12, 2000) (unpublished)-Reliance Standard appealed a summary judgment by the magistrate judge in favor of Bucks on his claim for long-term disability benefits for headaches and depression. Reliance Standard stated there was insufficient objective medical evidence to show that Bucks was totally disabled and unable to perform his job as an executive engineer. This court found that Reliance Standard did not abuse its discretion in denying Bucks' claim, considering the lack of "objective evidence" of debilitating headaches and depression. See detailed analysis.
Karr v. Central
States, Southeast & Southwest Areas Pension Fund, 2000 U.S. App. LEXIS 11464 (6th
Cir. May 11, 2000) (unpublished)
Secretary, U.S. Dept. of Labor v. Jackson County Hospital, Inc., 2000 U.S. App. LEXIS 10712 (6th Cir. May 10, 2000) (unpublished)-The Department of Labor (DOL) filed suit against Jackson County Hospital, Inc., seeking restitution on behalf of participants in two self-funded health plans at the hospitals. The DOL alleged numerous violations of ERISA and breach of fiduciary duties. Eventually, the DOL negotiated a dismissal, after which Jackson County Hospital and its president, William Brownlow, filed a motion for attorneys' fees pursuant to the Equal Access to Justice Act (EAJA). The district court denied the motion, and this court affirmed. See detailed analysis.
Palen
v. KMart Corp., 2000 U.S.
App. LEXIS 10780 (6th Cir. May 9, 2000) (unpublished)-
Gibbs
v. ITT Hartford,
2000 U.S. App. LEXIS 10790 (6th Cir. May 9, 2000) (unpublished)
Halvorson v. Boy Scouts of America, 2000 U.S. App. LEXIS 9648 (6th Cir. May 3, 2000) (unpublished)-Charles Halvorson sued the Boy Scouts of America alleging that the Boy Scouts forced him to resign or to agree not to take short-term medical leave for back problems. This court affirmed the district court's summary judgment against Halvorson on the grounds that Halvorson's resignation contained a valid waiver of the right to sue on ERISA grounds (although not ADEA grounds.) See detailed analysis.
Welsch
v. Empire Plastics, Inc.,
2000 U.S. App. LEXIS 11792 (6th Cir. May 19, 2000) (unpublished)-A group of
former employees filed suit against Empire Plastics, alleging constructive
discharge in violation of ERISA § 510. This court affirmed the district court's summary judgment in
favor of Empire, after finding that the plaintiffs failed to make a prima facie
case under § 510.
Wal-Mart
Stores, Inc. v. Wells, 213 F.3d 398 (7th Cir. 2000)-
In this appeal, a plan administrator brought suit against a beneficiary
Wells, for reimbursement of funds she recovered in a settlement of a auto
accident tort action against a third party.
Wells refused, claiming that the plan should contribute a pro rata share
of her attorneys' fees, since she incurred the attorneys’ fees for the plan's
benefit as well as her own.
Board of Trustees, Sheet Metal Workers' National Pension Fund, v. Elite Erectors, Inc., 212 F.3d 1031 (7th Cir. 2000)-Several pension funds sued Elite Erectors, and two alleged "alter ego" entities, for failure to contribute to the fund and other trusts pursuant to a collective bargaining agreement. The district court entered judgment, holding all three defendants jointly and severally liable for the $18,000 debt. When the funds initiated collection proceedings, the two alleged "alter ego" entities, Skylight Consultants of America, Inc. and one Mary Lowry, residents of Indiana, filed a motion under Fed. R. Civ. P. 60(b)(4), asking the district judge in Indiana to declare the Virginia judgment void because, they asserted, the Eastern District of Virginia lacked personal jurisdiction over them. This court pointed out that 29 U.S.C. § 1132(e)(2) provides nationwide service to bring "a defendant" into the action, not just those persons liable under ERISA—a "step that would conflate jurisdiction with the merits." See detailed analysis.
Sandstrom
v. Cultor Food Science, Inc.,
214 F.3d 795 (7th Cir. 2000)-Following
an acquisition of American Xyrofin, by Cultor U.S. Inc., a newly created
subsidiary, Cultor Food Science sought to discharge certain former Xyrofin
employees. Kenneth Sandstrom filed suit under 29 U.S.C. § 1132 (a)(1)(B),
contending that Cultor's severance offer to another Xyrofin employee
demonstrated that it had an "informal plan for severance benefits"
that the court should apply to him also.
This court, however, found no basis for alleging a plan amendment. "Bilateral arrangements are compatible with ERISA and do not modify the plan applicable to other employees who did not receive the offers or estop the employer to enforce the plan's written terms." Frahm v. Equitable Life Assurance Society, 137 F.3d 955, 960 (7th Cir. 1998). See detailed analysis.
Downs v. World Color Press, 214 F.3d 802 (7th Cir. 2000)-This court affirmed the district court's summary judgment against Downs on his claim that oral and written representations to him by company officials entitled him to greater retirement benefits. See detailed analysis.
Taylor v. United States, 212 F.3d 395 (8th Cir. 2000)-Bankruptcy court did not err when it included debtor's ERISA-qualified pension in its calculation of his disposable income or when it found the petition should be dismissed as an abuse of the bankruptcy system. See detailed analysis.
Thomas v. Silgan Containers Corp., 2000 U.S. App. LEXIS 9039 (9th Cir. May 3, 2000) (unpublished)-This court reversed and remanded the district court's summary judgment against Thomas. See detailed analysis.
Evans v. Unocal Termination Allowance Plan, 2000 U.S. App. LEXIS 11773 (9th Cir. May 22, 2000) (unpublished)-This court affirmed the district court's summary judgment in favor of Uncoal after it denied severance benefits on the ground that Appellants became a "purchaser" of the Unocal facilities employed the Appellants. See detailed analysis.
Willmar Electric Service, Inc. v. Cooke, 212 F.3d 533 (10th Cir. 2000)-The Tenth Circuit affirmed the holding that ERISA does not preempt a Colorado statute requiring a licensed journeyman electricians to supervise apprentices performing electrical work in Colorado on a one-to-one basis. See detailed analysis.
Pitman v. Blue Cross and Blue Shield of Oklahoma, 213 F.3d 550 (10th Cir. 2000)- In this appeal, the court agreed with the district court that a "conflict of interest" existed on the part of Blue Cross Blue Shield. The court also agreed that the district court should consider the conflict in assessing the deference due to Blue Cross Blue Shield's decision to deny coverage for Gail Pitman's high-dose chemotherapy with autologous bone marrow transplant. See detailed analysis.
Burks
v. American Cast Iron Pipe Co.,
212
F.3d 1333 (11th Cir. 2000)-Plaintiffs,
who retired before Sept. 2, 1974, the enactment date of ERISA, filed suit
against American Cast Iron Pipe Company when it ceased providing free
medications as part of its health plan.
The plaintiffs sued in Alabama state court and alleged breach of
contract, fraud, unjust enrichment, and conversion. The
district court denied the plaintiffs' request for discovery (finding that ERISA
would preempt the plaintiffs' state law claims regardless of discovery findings)
and entered summary judgment against them.
This court affirmed in part and reversed in part. However, as to plaintiffs' state claims for benefits based on pre-ERISA documents, the district court erred in applying ERISA substantive law retroactively to pre-1975 responsibilities. See detailed analysis.
White v. Aetna Life Insur. Co., 210 F.3d 412 (D.C. Cir. 2000)-This court reversed the district court’s grant of summary judgment, holding that Aetna violated 29 U.S.C. § 1133 when it failed to inform the appellant of an important reason for denying her claim. Therefore, it could not deny Ms. White's appeal on the basis of untimeliness. See detailed analysis.
