Justia U.S. 1st Circuit Court of Appeals Opinion SummariesArticles Posted in ERISA
Doe v. Standard Insurance Co.
Plaintiff worked at a Maine law firm for more than twenty-five years and, for many years, was an equity partner. In 2012, Plaintiff filed a long term disability (LTD) claim with Defendant Standard Insurance Company, the claim administrator and insurer of the employee welfare benefit plan offered by Plaintiff’s law firm to its employees. The plan was insured by an LTD policy, also issued by Defendant and which covered Plaintiff. Defendant told Plaintiff that it would approve her claim and that it would use January 28, 2012 as the disability onset date. This appeal concerned only what disability onset year should be used to calculate Plaintiff’s monthly disability amount, Plaintiff arguing that the onset date was on November 2011. The district court entered judgment for Defendant. The First Circuit reversed, holding that Defendant’s decision to use the 2012 onset date was arbitrary and capricious. Remanded to the district court with direction to order Defendant to award Plaintiff retroactive benefits based on a disability onset date of no later than 2011. View "Doe v. Standard Insurance Co." on Justia Law
Stephanie C. v. Blue Cross Blue Shield of Massachusetts HMO Blue, Inc.
Plaintiff brought this case pursuant to the Employee Retirement Income Security Act (ERISA), seeking reimbursement for certain expenses connected with the treatment of her teenage son. The plan administrator, Blue Cross Blue Shield of Massachusetts HMO Blue, Inc. (BCBS) denied the portions of Plaintiff’s claim that were in dispute in this case. The district court upheld BCBS’s action. The First Circuit affirmed, holding that, applying the plain language of the ERISA plan, the clear weight of the evidence dictated a finding that the disputed charges were not medically necessary, as defined in the plan, and therefore were not covered. View "Stephanie C. v. Blue Cross Blue Shield of Massachusetts HMO Blue, Inc." on Justia Law
Rodriguez-Lopez v. Triple-S Vida, Inc.
On her last day of work with Mova Pharmaceutical Corporation, Nilda Rodriguez-Lopez (Rodriguez) began experiencing symptoms. Rodriguez was diagnosed with several physical and mental conditions and filed a claim for long-term disability (LTD) benefits under Mova’s employee welfare benefits plan (the Plan). Triple-S Vida, Inc. denied Rodriguez’s application for LTD benefits, finding she did not meet the Plan’s definition of disabled. After she exhausted her administrative remedies, Rodriguez filed suit. The district court granted Triple-S’s motion for summary judgment, concluding that Triple-S’s denial of LTD benefits was neither arbitrary nor capricious. Rodriguez appealed, claiming that the Plan did not reflect a clear grant of discretionary authority to Defendant, and therefore, Triple-S’s determination to deny her LTD benefits was subject to the de novo standard of review. The First Circuit vacated the judgment, holding that the Plan did not confer discretionary authority upon Triple-S, and therefore, de novo review applied. Remanded. View "Rodriguez-Lopez v. Triple-S Vida, Inc." on Justia Law
Prime Healthcare Services – Landmark LLC v. United Nurses & Allied Professionals, Local 5067
This appeal concerned a dispute between employees represented by a Union and their successor employer. The parties agreed to arbitrate this dispute regarding change in the terms of pension provision in a collective bargaining agreement. The district court refused to compel arbitration on the grounds that ERISA preempted the Union’s claims, and this, in turn, presented an issue of arbitrability properly decided by a judge, not an arbitrator. The First Circuit vacated the order of the district court and remanded with instructions to grant the Union’s motion to compel arbitration, holding that the issue of ERISA preemption in this case was not an issue of arbitrability but, rather, one that was squarely for the arbitrator to decide. View "Prime Healthcare Services - Landmark LLC v. United Nurses & Allied Professionals, Local 5067" on Justia Law
Vendura v. Boxer
In 1993, Vendura was hired by TRW Inc. and became a participant in the TRW Salaried Pension Plan. In 2002, Northrop Grumman Corp. acquired TRW and renamed the company (herein referred to as NGSMC). After NGSMC attempted to terminate Vendura’s employment Vendura challenged the attempt, and Vendura and NGSMSC signed a settlement agreement providing that Vendura would remain an employee of NGSMSC under certain conditions. In 2013, Vendura filed a claim for pension benefits to the Administrative Committee for the NGSMSC Plan, arguing that he was entitled to twenty years of benefit service under the settlement agreement. The Administrative Committee informed Vendura that he was eligible for a pension reflecting only twelve years of service. Vendura filed an eight-count complaint against Defendants, claiming, inter alia, a violation of ERISA. The district court granted summary judgment for Defendants. At issue on appeal concerned the number of “years of benefit service” that should be credited to Vendura in calculating his pension benefits under his pension plan. The First Circuit granted summary judgment to Defendants, holding that the Administrative Committee properly calculated Vendura’s pension benefits. View "Vendura v. Boxer" on Justia Law
Troiano v. Aetna Life Insurance Co.
While working at a subsidiary of General Dynamics Corporation (GDC), Plaintiff participated in GDC’s long-term disability (LTD) plan, which was funded and administered by Aetna Life Insurance Company. Plaintiff became disabled in 2003 and applied for plan benefits. Aetna approved her claim until 2010, when it began offsetting Plaintiff’s monthly LTD benefits by her gross Social Security income. Plaintiff sued Aetna and GDC, alleging that Aetna breached its fiduciary duty and seeking a declaration that her past and future LTD benefits should be offset against the Social Security Disability Insurance (SSDI) benefits she was awarded minus any income taxes she was assessed on those benefits. The district court granted summary judgment in favor of Defendants, thus affirming Aetna’s interpretation of the plan’s offset provision. The First Circuit affirmed, holding (1) the plan permits Aetna to offset LTD benefits by the gross amount of SSDI benefits; and (2) the district court did not err in denying discovery. View "Troiano v. Aetna Life Insurance Co." on Justia Law
O’Shea v. UPS Retirement Plan
Brian O’Shea worked for UPS for thirty-seven years. As an employee of UPS, O’Shea participated in the UPS Retirement Plan. O’Shea became eligible for retirement in 2009 and decided to retire at the end of that year. In 2008, O’Shea was diagnosed with cancer. One week before his official retirement date but after his final day of work, O’Shea died. UPS Retirement Plan Administrative Committee informed O’Shea’s beneficiaries that, under the circumstances, they were deprived of ten years of payments under the annuity plan. O’Shea’s beneficiaries filed suit in district court seeking recovery of the ten years of annuity payments allegedly guaranteed under the UPS Retirement Plan. The district court granted summary judgment in favor of UPS. The First Circuit affirmed, holding (1) the district court did not err in concluding that UPS’s interpretation of the plan was not arbitrary or capricious; and (2) the district court did not err in dismissing the beneficiaries’ claim for equitable relief. View "O'Shea v. UPS Retirement Plan" on Justia Law
Kelley v. Fidelity Mgmt. Trust Co.
Plaintiffs, retirement-plan participants and one plan administrator, filed a putative class action on behalf of the plans themselves, contending that the plans were being cheated of certain plan assets. Specifically, Plaintiffs alleged that Defendants, various Fidelity entities that had trust agreements with the plans, were dealing with plan assets in breach of fiduciary duties imposed by the Employee Retirement Income Security Act. The district court dismissed the complaint for failure to state a claim. The First Circuit affirmed, holding that the district court did not err in its judgment. View "Kelley v. Fidelity Mgmt. Trust Co." on Justia Law
Santana-Diaz v. Metropolitan Life Ins. Co.
Appellant participated in Shell Chemical Yabucoa, Inc.’s employee welfare benefit plan, which Shell provided through a group insurance policy issued by Metropolitan Life Insurance Company (MetLife). On November 23, 2008, Appellant received his first long-term disability benefit payment. On April 5, 2010, Metlife sent Appellant a letter informing him that his benefits would expire on November 22, 2010. On November 24, 2010, in another letter, MetLife denied Appellant’s claim for an extension of benefits. On August 19, 2011, MetLife issued a final denial letter. Neither the November 24, 2010 letter nor the August 19, 2011 letter included a time period for filing suit. On August 18, 2013, Appellant filed suit, alleging improper denial of benefits. The district court dismissed the complaint as time-barred. The First Circuit reversed, holding (1) if a plan administrator fails to include the time limit for filing suit in its denial of benefits letter, the plan administrator is not in substantial compliance with Employee Retirement Income Security Act regulations, and the violation is per se prejudicial to the claimant; and (2) as a consequence of MetLife’s failure to include the time limit for filing suit in its final denial letter, the limitations period was rendered inapplicable, and therefore, Appellant’s suit was timely filed. Remanded. View "Santana-Diaz v. Metropolitan Life Ins. Co." on Justia Law
Sirva Relocation, LLC v. Golar Richie
In Sprint Commc’ns, Inc. v. Jacobs, the Supreme Court revisited the doctrine of abstention enunciated in Younger v. Harris. That doctrine requires federal courts, in the absence of extraordinary circumstances, to refrain from interfering with certain state proceedings. In this case, David Knight, an employee of Sirva Relocation, LLC, filed a charge of discrimination with the Massachusetts Commission Against Discrimination (MCAD) alleging that Sirva and Aetna Life Insurance Company (together, Appellants) had discriminated against him on the basis of disability in violation of Mass. Gen. Laws ch. 151B and the Americans with Disabilities Act (ADA). Appellants filed a federal complaint against the Commonwealth of Massachusetts, the MCAD, its commissioners, and Knight, asking the court to enjoin the MCAD proceeding on the basis that ERISA preempted the chapter 151B claim. The MCAD and Knight moved to dismiss the complaint, entreating the district court to abstain. While the case was pending, the Supreme Court decided Sprint. The district court dismissed the federal court action, concluding that Younger abstention was appropriate in this case. The First Circuit affirmed the district court’s decision to abstain and further clarified its own case law concerning the exception to the Younger doctrine for facially conclusive claims of preemption. View "Sirva Relocation, LLC v. Golar Richie" on Justia Law