Justia U.S. 1st Circuit Court of Appeals Opinion SummariesArticles Posted in ERISA
Shields v. United of Omaha Life Insurance Co.
The First Circuit affirmed in part and vacated in part the order of the district court granting summary judgment in favor of United of Omaha Life Insurance Company (United) and against Lorna Shields on her claims for recovery of plan benefits under 29 U.S.C. 1132(a)(1)(B) of the Employee Retirement and Investment Security Act (ERISA) and breach of fiduciary duty under 29 U.S.C. 1132(a)(3) of ERISA, holding that the district court erred in part.Shields was the beneficiary of a life insurance policy that the decedent, her late husband, acquired through his employer. Shields sued United, bringing claims for recovery of plan benefits and breach of fiduciary duty under ERISA. The district court granted summary judgment for United on both claims. The First Circuit vacated the judgment in part, holding (1) there was no error in the district court's summary judgment rulings with respect to the claim for recovery of benefits; but (2) the district court's grounds for granting summary judgment for United on the breach of fiduciary duty claim did not hold up. View "Shields v. United of Omaha Life Insurance Co." on Justia Law
Ministeri v. Reliance Standard Life Insurance Co.
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
United Steelworkers v. National Grid
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
N.R. v. Raytheon Co.
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
Alexandre v. National Union Fire Insurance Co. of Pittsburgh
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
Jette v. United of Omaha Life Insurance Co.
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
Ovist v. Unum Life Insurance Company of America
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
Wong v. FMR LLC
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
Doe v. Harvard Pilgrim Health Care, Inc.
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
Coffey v. New Hampshire Judicial Retirement Plan
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