Justia U.S. 1st Circuit Court of Appeals Opinion Summaries

Articles Posted in ERISA
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The First Circuit affirmed the judgment of the district court in favor of an employee's widow in this insurance dispute, holding that the employee did not lose life insurance coverage under his employer's group policy after he developed a brain tumor that disrupted his usual work.Plaintiff, the employee's widow, submitted a statement to Insurer claiming approximately $1 under her late husband's life insurance policy. Insurer denied the claim. Plaintiff then sued, alleging wrongful denial of benefits under section 502(a) of ERISA, 29 U.S.C. 1132(a)(1)(B), (a)(3). The insurance company denied life insurance coverage on the grounds that the employee's coverage under the policy had lapsed. The district court granted summary judgment for Plaintiff. The First Circuit affirmed, holding (1) because the policy language invoked by Insurer in this case was less than clear the rule that ambiguous terms in an insurance policy should be read in favor of coverage applied; and (2) the employee was covered at the time of his demise. View "Ministeri v. Reliance Standard Life Insurance Co." on Justia Law

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The First Circuit reversed the judgment of the district court denying arbitration requested by two unions - the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union and the United Steelworkers Local 12203 (collectively, Union) - on behalf of former two employees of the Boston Gas Company (Company) as to their claims for pension benefits, holding that this matter called for arbitration.The Union represented the two members in filing grievances regarding their underpaid pensions. The Union submitted the grievances to the Joint Pension Committee, which was unable to resolve the dispute. The Union subsequently sought arbitration over the grievances, but the Company refused to arbitrate. The First Circuit reversed, holding that it was up to an arbitrator, not a court, to determine the matters at issue in this case. View "United Steelworkers v. National Grid" on Justia Law

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The First Circuit affirmed the decision of the district court granting Defendant's motion to dismiss as to count one of Plaintiffs' complaint and reversed the dismissal and remanded for further proceedings on counts two through four, holding that dismissal was improper as to the remaining three counts.Plaintiffs, S.R. and T.R. and their child N.R., brought this action against Raytheon Company, T.R.'s employer, after United Healthcare, which administered the company's health insurance plan, refused to pay for N.R.'s speech therapy, alleging various violations of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001, et seq. The district court granted Defendant's motion to dismiss in full. The First Circuit held (1) the district court properly dismissed count one of the complaint; but (2) the dismissal of Plaintiffs' remaining claims was improper. View "N.R. v. Raytheon Co." on Justia Law

Posted in: ERISA, Insurance Law
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The First Circuit affirmed the decision of the district court upholding Defendant National Union Fire Insurance Company of Pittsburg, PA's denial of accidental death insurance benefits to Plaintiff following her husband's death because he had committed suicide, holding that the district court did not err.Plaintiff enrolled in an accidental death and dismemberment insurance policy, an employer-sponsored welfare plan affording participants like Plaintiff rights and protections under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Plaintiff's husband was insured for a death benefit, with Plaintiff named as the beneficiary. After Plaintiff's husband fell nine stories from a hotel balcony and died, Plaintiff submitted a claim under the policy for accidental death benefits. Defendant denied benefits, concluding that Plaintiff's husband committed suicide, precluding benefits. Plaintiff filed suit under section 502(a)(1)(B) of ERISA seeking the benefits provided for under the policy. The district court granted summary judgment for Defendant. The First Circuit affirmed, holding that Defendant's denial of accidental death benefits was not arbitrary, capricious, or an abuse of discretion. View "Alexandre v. National Union Fire Insurance Co. of Pittsburgh" on Justia Law

Posted in: ERISA
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The First Circuit vacated the entry of summary judgment in this case brought by Plaintiff seeking relief from the termination of her benefits under the civil enforcement provision of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1), holding that Defendant did not provide Plaintiff a full and fair review of her claim, and Plaintiff was prejudiced by Defendant's procedural violation.Plaintiff participated in a long-term disability plan sponsored by her employer and funded and administrated by Defendant. The Plan was subject to ERISA. When Defendant terminated Plaintiff's disability benefits, Plaintiff filed an internal appeal review. Defendant upheld the termination of benefits, relying in part on a report written by a doctor hired by Defendant to examine Plaintiff. Plaintiff was not given a copy of the doctor's report. Plaintiff sought relief under ERISA's civil enforcement provision, arguing that, in failing to provide her with an opportunity to respond to the doctor's report, Defendant failed to provide her with a full and fair review, as required by ERISA and its implementing regulation. The district court granted summary judgment for Defendant. The First Circuit vacated the summary judgment, holding that Defendant committed a procedural violation, and Plaintiff was prejudiced thereby. View "Jette v. United of Omaha Life Insurance Co." on Justia Law

Posted in: ERISA
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The First Circuit affirmed the judgment of the district court granting summary judgment to Defendant and dismissing Plaintiff's action brought under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq, holding that summary judgment was properly granted.Plaintiff was a participant in her employer's long-term disability plan, which was insured and administered by Defendant, Unum Life Insurance Company of America, and governed by ERISA. In 2011, Plaintiff was granted benefits under the plan. In 2015, Defendant terminated Plaintiff's benefits. Plaintiff brought this action seeking recovery and reinstatement of her benefits. The district court granted summary judgment for Defendant. The First Circuit affirmed, holding (1) Defendant's requirement that Plaintiff provide objective evidence of her functional limitations in order to avoid a limitation in the plan was reasonable; and (2) substantial evidence supported Defendant's determination that Plaintiff lacked objective proof in her functional limitations. View "Ovist v. Unum Life Insurance Company of America" on Justia Law

Posted in: ERISA
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The First Circuit affirmed the judgment of the district court dismissing this putative class action complaint brought under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., holding that the district court did not err or abuse its discretion.Plaintiffs claimed that FMR LLC and several related Fidelity entities and affiliates (collectively, Fidelity) violated fiduciary duties it owed to its customer plans and their participants by exacting and retaining certain fees. The fees were exacted from mutual funds for the privilege of being placed on the menu of investment options Fidelity made available to 401(k) plans that contract with it to receive certain investment opportunities and services. The district court granted Fidelity's motion to dismiss for failure to state a claim. The First Circuit affirmed, holding that the district court properly dismissed the complaint. View "Wong v. FMR LLC" on Justia Law

Posted in: ERISA
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In this ERISA action, the First Circuit affirmed the rulings of the district court entering judgment for Defendants on remand and refusing to award Plaintiff attorneys' fees for her success on a prior appeal, holding that there was no clear error on the part of the district court.Plaintiff spent several months at a residential mental health treatment center. Defendants covered certain costs of Plaintiff's treatment but denied coverage for a four-month period on the grounds that Plaintiff could have stepped down to a lower level of treatment during that period. Plaintiff brought suit seeking de novo review of her claim for coverage of the four-month period under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001-1461. The district court entered summary judgment for Defendants. The First Circuit vacated the judgment and remanded so the district court could consider additional evidence. On remand, the district court again granted summary judgment for Defendants. The First Circuit affirmed, holding (1) it was not clear error for the district court to conclude that, at the beginning of the four-month period, Plaintiff's continued stay at the residential facility was not medically necessary; and (2) there was no clear error in the district court's decision not to award attorney's fees. View "Doe v. Harvard Pilgrim Health Care, Inc." on Justia Law

Posted in: ERISA
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The First Circuit held that the New Hampshire Judicial Retirement Plan (Plan) does not allow a former judge who resigned with sufficient years of creditable service, but before reaching the minimum retirement age, to receive a Service Retirement Allowance (SRA) upon later reaching the retirement age.Plaintiff was fifty-four years old when she resigned from her position as a superior court justice for the state of New Hampshire. Plaintiff served in that position for sixteen-and-a-half years. At the age of sixty-one, Plaintiff applied for an SRA. The Board of Trustees of the Board of Trustees (Board) of the Plan denied her application. Plaintiff filed suit against the Plan seeking a declaratory judgment that she was eligible for an SRA. The district court granted summary judgment in favor of the Plan as to Plaintiff's claim for violation of N.H. Rev. Stat. 100-C, 5, concluding that the plain language of the statute requires a judge to be in active service when she elects to retire and claim a service retirement allowance. The First Circuit affirmed, holding that, under the circumstances of this case, Plaintiff was not eligible to receive an SRA on her application. View "Coffey v. New Hampshire Judicial Retirement Plan" on Justia Law

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In this insurance dispute, the First Circuit directed entry of summary judgment for Zurich American Insurance Company, holding that Zurich's decision to deny the insured's claim was supported by substantial evidence.Denise Arruda filed a claim for death benefits following the death of her husband, Joseph Arruda, in a car accident. Zurich denied the claim, concluding that Joseph's death was not within the coverage clause of the policy because the death was not independent of all other causes and that it was caused or contributed to by his pre-existing health conditions. Denise brought this action under 29 U.S.C. 1132(a)(1)(B) alleging that Zurich violated ERISA by denying the insurance benefits. The district court entered summary judgment in favor of Denise, concluding that substantial evidence did not support Zurich's decision. The First Circuit reversed, holding that Zurich's conclusion that Joseph's death was caused or contributed to by pre-existing medical conditions was not arbitrary or capricious and was supported by substantial evidence. View "Arruda v. Zurich American Insurance Co." on Justia Law