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

In a previous decision of an appeal of a case brought under the Employees Retirement Income Security Act of 1974, the First Circuit Court of Appeals agreed with Plaintiff that the First Circuit should not longer apply the arbitrary and capricious standard of review to certain benefits actions. Because the Court found the record was inadequate to permit de novo review on Plaintiff’s entitlement to benefits, the Court remanded the case for further development of the evidence. Plaintiff subsequently filed a motion seeking an award of attorney’s fees and costs for the litigation in the district court and on appeal. The First Circuit remitted Plaintiff’s fee request to the district court for a determination in the first instance of the proper amount of the award, holding (1) the Court’s prior decision afforded Plaintiff a degree of success on the merits that qualified her for an award of fees; and (2) an award of fees is appropriate and properly ordered at this time.View "Gross v. Sun Life Assurance Co. of Canada" on Justia Law

The City of Quincy passed an ordinance demanding that bidders on municipal public works projects engage in a specific type of apprentice training program. Plaintiffs, a trade association of construction companies and two of its members, sued the City in federal district court asserting that the Employee Retirement Income Security Act (ERISA) preempted the ordinance’s apprentice training requirement. The district court granted summary judgment in favor of Plaintiffs and granted Plaintiffs’ motion for attorney fees under ERISA’s fee-shifting provision. The First Circuit affirmed the district court’s grant of summary judgment but reversed the fee award, holding (1) the reach of ERISA’s preemption provision extends to the ordinance at issue; and (2) because there was no appropriate “participant, beneficiary, or fiduciary” to whom fees could lawfully be awarded in this case, the fee award must be set aside. Remanded.View "Merit Constr. Alliance v. City of Quincy" on Justia Law

Plaintiffs challenged an insurance company's use of "retained asset accounts" (RAAs) as a method of paying life insurance benefits in the ERISA context. They presented the district court with two basic questions: (1) whether the insurer's method of paying death benefits in the form of RAAs constitute self-dealing in plan assets in violation of ERISA section 406(b); and (2) whether this redemption method offended the insurer's duty of loyalty toward the class of beneficiaries in violation of ERISA section 404(a). The district court answered the first question in favor of the insurer and the second in favor of the plaintiff class. The court then awarded class-wide relief totaling more than $12,000,000. Both sides appealed. Upon review, the First Circuit Court of Appeals agreed with the district court that the insurer's use of RAAs in this case did not constitute self-dealing in plan assets. However, the Court disagreed with the district court's answer to the second question and held that the insurer's use of RAAs did not breach any duty of loyalty owed by the insurer to the plaintiff class. View "Merrimon, et al v. Unum Life Insurance Company" on Justia Law

Plaintiff received coverage under Johnson & Johnson’s Long-Term Disability Plan while working for a subsidiary of Johnson & Johnson. Later, Johnson & Johnson and Medical Card System, Inc. (together, Appellees) terminated Plaintiff’s long-term disability benefits. The district court upheld the denial, holding that the plan administrator had ample basis for finding Plaintiff did not cooperate fully during the Functional Capacity Examination (FCE) and was thus ineligible for continuing benefits. Plaintiff again appealed, arguing, among other things, that the plan administrator abused its discretion in crediting an examination by a physical therapist over the opinion of his treating physician. The First Circuit Court of Appeals affirmed, holding (1) the plan administrator’s finding that Plaintiff was uncooperative during his final FCE was supported by substantial evidence, and therefore, the administrator’s decision to terminate Plaintiff’s long-term disability benefits was neither arbitrary nor capricious; and (2) the administrator did not abuse its discretion in determining whether there existed grounds for termination of Plaintiff’s benefits. View "Ortega-Candelaria v. Johnson & Johnson" on Justia Law

Plaintiff was hired by Employer in 1983. Plaintiff was covered by a short-term disability plan, and the Life Insurance Company of North America (“LINA”) had the authority to decide questions of eligibility for coverage or benefits under the plan. After Plaintiff underwent back surgery in 2009, LINA at first granted but then denied Plaintiff disability benefits. In 2010, Plaintiff sued LINA, Employer, and others in Puerto Rico court, seeking review of the benefits denial. LINA later removed the action to the District of Puerto Rico. Ultimately, the district court (1) found LINA’s decision was not arbitrary and capricious because Plaintiff failed to produce sufficient medical evidence of disability, and (2) dismissed Plaintiff’s claim against Employer for failure to plead it with specificity. Plaintiff appealed. The First Circuit Court of Appeals dismissed Plaintiff’s appeal on procedural grounds because Plaintiff committed numerous procedural errors, which precluded intelligent review. View "Gonzalez-Rios v. Hewlett Packard PR Co." on Justia Law

Union-affiliated benefit funds (collectively, the Fund) sued Employer to recover unpaid employee-related remittances allegedly due under a collective bargaining agreement (CBA). The Fund also sought attorneys’ fees and costs pursuant to both the CBA and ERISA. The district judge awarded the Fund $26,897 in damages, and, in a separate judgment, awarded $18,000 in attorneys’ fees and $16,688 in expenses. Both parties appealed. The First Circuit Court of Appeals reversed the district court’s determination of damages, but the Supreme Court reversed, concluding that the First Circuit lacked jurisdiction to review the damage judgment. On remand, the First Circuit reinstated the cross-appeals challenging the separate judgment for fees and costs and affirmed the district court’s order awarding attorneys’ fees and expenses, holding that the award was not an abuse of the judge’s discretion. View "Int'l Union v. Ray Haluch Gravel Co." on Justia Law

Plaintiff, who worked for Metropolitan Life Insurance Co. (“MetLife”), made a claim for long-term disability benefits (LTD). In 2005, the claim was approved. That same year, MetLife denied Plaintiff’s assertion that he was entitled to a larger payment calculation. In 2012, Plaintiff filed suit against MetLife under the Employee Retirement Income Security Act of 1974 (ERISA), claiming that MetLife had been underpaying his monthly benefits since 2005. The district court granted MetLife’s motion for summary judgment, concluding that Plaintiff’s suit was barred by the six-year statute of limitations. The First Circuit Court of Appeals affirmed, thus rejecting Plaintiff’s theory that the LTD plan must be analogized to an installment plan so as to alter the accrual date of his claim, holding that Plaintiff’s claim against MetLife was barred by the statute of limitations. View "Riley v. Metro. Life Ins." on Justia Law

This case concerned a plumbers and pipefitters union ("the Union"), which established employee benefits plans. Among the pension benefits promised to Union employees were "banked hour" benefits, which were retroactively conferred during the course of employment. The Pension Trust sought to eliminate the benefits in an attempt to meet its obligations to a larger group of plan participants. Plaintiffs, now-retired union employees, filed this action against the Trustees, alleging that the cuts, which were effectuated through a plan amendment, violated the anti-cutback provisions ERISA, which protects "accrued benefits" against reduction by amendment. The district court entered summary judgment for Plaintiffs. The First Circuit Court of Appeals affirmed, holding that Plaintiffs' benefits were in fact "accrued" and that the plan amendment, if implemented, would violate the anti-cutback provisions of ERISA. View "Bonneau v. Plumbers & Pipefitters Local Union 51 Pension Trust Fund" on Justia Law

Plaintiff, the Chairman of the Trustees of the Rhode Island Bricklayers Benefits Funds (the Funds), sued Union Stone Inc., alleging that Union Stone had failed to pay the full amount of fringe benefit contributions due for work performed in Massachusetts and Connecticut by members of the International Union of Bricklayers and Allied Craftworkers pursuant to a collective bargaining agreement. After a trial, the district court entered judgment in favor of the Funds, awarding the unpaid contributions, interest, and attorneys' fees. The First Circuit Court of Appeals affirmed, holding that the district court did not err in (1) refusing to enforce a purported settlement agreement between the parties; (2) admitting certain evidence on the ground that it was tainted by violations of the discovery rules; (3) declined to impose sanctions; and (4) awarding interest and attorneys' fees. View "Enos v. Union Stone, Inc." on Justia Law

Appellant was placed on disability leave from work. Appellant was covered under a long term disability (LTD) policy that her employer obtained from Medical Group Insurance Services (MGIS). The policy was written by Sun Life Assurance Company (Sun Life). After leaving her job, Appellant filed a claim with MGIS seeing long term disability benefits. Sun Life denied Appellant's request for benefits. Appellant filed an action against Sun Life, asserting various state law claims. The federal district court dismissed the action based on ERISA preemption. Appellant then amended her complaint to add ERISA claims and asked the district court to apply de novo review in its evaluation of her ERISA claims. The court denied the motion and granted summary judgment for Sun Life, concluding that Sun Life's decision to deny benefits was not arbitrary and capricious, and thus complied with ERISA's requirements. The First Circuit Court of Appeals vacated the judgment, holding (1) the safe harbor exception to ERISA did not apply to the policy covering Appellant, and therefore, Appellant's state law claims were preempted; but (2) the benefits denial was subject to a de novo review, rather than the highly deferential "arbitrary and capricious" review prescribed for certain ERISA benefits decisions. Remanded. View "Gross v. Sun Life Assurance Co. of Canada" on Justia Law