Justia U.S. 1st Circuit Court of Appeals Opinion SummariesArticles Posted in ERISA
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
Niebauer v. Crane & Co., Inc.
Plaintiff brought this complaint under the Employee Retirement Income Security Act (ERISA), alleging (1) the administrator of his former employer’s executive severance plan denied him severance benefits after improperly determining that he had voluntarily retired from his position, and (2) his former employer impermissibly interfered with his protected rights under the plan. The district court granted summary judgment for Defendants on both counts. The First Circuit (1) affirmed the district court’s judgment with regard to the plan administrator’s decision to deny Plaintiff’s claim for benefits, holding the decision was both supported by substantial evidence and procedurally proper; but (2) vacated the district court’s judgment as to the interference claim, holding that the district court relied on the incorrect standard in assessing the interference claim. Remanded for application of the appropriate standard of review. View "Niebauer v. Crane & Co., Inc." on Justia Law
McDonough v. Aetna Life Ins. Co.
Appellant was eligible for disability benefits through an employee welfare benefit plan underwritten by Aetna Life Insurance Company. Appellant successfully applied for long-term disability (LTD) benefits under his plan in 2009. Later that year, Appellant’s LTD benefits were terminated. Appellant brought this suit against Aetna under the Employee Retirement Income Security Act of 1974 alleging wrongful termination of benefits. The federal district court granted summary judgment for Aetna on the benefits-termination claim but applied a $5,000 penalty against Aetna for its failure to produce all relevant plan documents within the statutorily prescribed time. The First Circuit (1) vacated summary judgment with respect to the termination of disability benefits and remanded the issue for further consideration by the claims administrator, holding that Aetna’s decision to terminate Appellant’s LTD benefits was not a reasoned determination; and (2) affirmed the district court’s imposition of a $5,000 penalty for the belated production of a plan document, holding that the amount of the penalty imposed was within the district court’s discretion. View "McDonough v. Aetna Life Ins. Co." on Justia Law
Dutkewych v. Standard Ins. Co.
Plaintiff was a participant in a disability plan (Plan), which was insured and administered by Defendant under ERISA. The Plan limited long-term disability (LTD) benefits to twenty-four months for a disability caused or contributed to by mental disorders, substance abuse, or other limited conditions. Defendant terminated Plaintiff’s benefits after twenty-four months after applying this limited conditions provision. After his unsuccessful administrative appeal, Plaintiff filed suit against Defendant for unpaid benefits. Specifically, Plaintiff argued that he had been diagnosed with chronic Lyme disease, a physical illness allegedly not limited under the terms of the Plan. The district court granted summary judgment in favor of Defendant. The First Circuit affirmed, holding that even if Plaintiff was disabled as a result of chronic Lyme disease, the mental disorder limitation nonetheless applied because Plaintiff's mental disorders contributed to his disability as of June 1, 2011. View "Dutkewych v. Standard Ins. Co." on Justia Law
Guerra-Delgado v. Banco Popular de P.R.
In 1997, Appellant began working for Banco Popular de Puerto Rico (BPPR). After Appellant retired in 2009, BPPR made a final calculation of Appellant’s pension, which yielded monthly payments significantly lower than earlier estimates had suggested. Seeking the higher amount he had expected, Appellant brought claims under ERISA, a theory of estoppel, and Puerto Rico contract law. The district court (1) dismissed the ERISA and contract claims, concluding that Appellant failed to state a claim under ERISA and that ERISA preempted the commonwealth claims; and (2) granted summary judgment against Appellant on the estoppel claim, concluding that the unambiguous terms of the benefits plan precluded a claim for estoppel. The First Circuit affirmed, holding (1) Appellant could not recover under ERISA because he could not be awarded relief under the terms of BPPR’s retirement plan; (2) the district court properly held that Appellant’s commonwealth claims “relate to” the ERISA-regulated plan and, accordingly, they were preempted; and (3) because Appellant did not show any ambiguity in the plan, his equitable estoppel claim necessarily failed. View "Guerra-Delgado v. Banco Popular de P.R." on Justia Law