Cockerill v. Corteva, Inc., No. 21-3966, __ F.R.D. __, 2023 WL 7986364 (E.D. Pa. Nov. 17, 2023) (Judge Michael M. Baylson)

For the second week in a row, we have chosen a Kantor & Kantor victory as the case of the week. In this week’s featured decision, a district court in Pennsylvania has certified two classes of workers who are participants in one of the oldest pension plans in the United States sponsored by the venerable chemical company E.I. DuPont de Nemours Company (“Historical DuPont”).

Two plan participants (later joined by two others) brought a putative class action suit in 2019, claiming that they were improperly denied the ability to qualify for early and optional retirement benefits they had long been promised following the merger of Historical DuPont and Dow Chemical Company to form the biggest chemical conglomerate in the world, and the subsequent spin-off of three companies: Dow Inc., Corteva, and DuPont de Nemours, Inc. (“New DuPont”). Both before and after the split, the plaintiffs worked at the same workplace for a company called DuPont, but because of corporate maneuvering which placed the pension plan (but not the workers) with Corteva, the participants were told that they had lost the ability to age into early retirement benefits and qualify for optional retirement benefits under the plan.   

The plaintiffs assert multiple claims on which they sought class certification. In Counts I and II, they seek clarification under ERISA Section 502(a)(1)(B) of their rights to early and optional retirement benefits under the terms of the plan. In Count IV, they allege that defendants breached their fiduciary duties in miscommunicating and failing to fully and clearly communicate the effect of the spin-off on their benefits. In Count V, they allege that by “splitting employees from Historical DuPont,” defendants acted to prevent them from attaining benefits in violation of ERISA Section 510. And in Count VI, plaintiffs allege that the defendants “retroactively applied an amendment to the Optional Retirement Benefits” in violation of ERISA’s anti-cutback provision, ERISA Section 205.    

The district court previously denied motions to dismiss and allowed plaintiffs to amend their complaint, among other things to expand the class definition to include workers both over and under the age of 50 who had at least 15 years of employment at the time of the spinoff on June 1, 2019. In this order, the judge certified two classes encompassing both age groups.

The court found that the plaintiffs had met all four requirements of Rule 23(a) with respect Counts I, II, IV, V and VI. The court reasoned that the plaintiffs established numerosity for both classes by showing 584 participants within the first class and thousands who met the second class definition. With respect to commonality, the court reasoned that “[b]oth classes share multiple common questions, that, when answered, will advance the litigation for all class members.” The court reasoned that “[b]ecause the claims center on how the Employers acted toward the classes as a whole, their disposition is common to all class members.” This held true with respect to all of the claims on which Plaintiffs sought class certification, including the fiduciary breach claim, which the court held did not depend on misrepresentations that were individualized in nature or require that plaintiffs show detrimental reliance.

Applying similar reasoning, the court also concluded that the typicality requirement was met by all plaintiffs except for Mr. Newton, whose circumstances the court found somewhat unique given that he was terminated at age 49. With respect to the adequacy of the class representatives, the court found that the interests of Mr. Cockerill, Mr. Major, and Mr. Benson were sufficiently aligned with those of the class members and that they had a sufficient degree of understanding of the case to adequately represent the class. Likewise, the court concluded that class counsel were adequate to represent the class.

Turning to the requirements of Rule 23(b), the court found certification appropriate under subsection (b)(1) for both classes, reasoning that “for each count, both classes prevail based not on individual members’ circumstances,” but on whether defendants improperly interpreted Plan documents, misrepresented or failed to inform participants how the spin-off would affect their benefits, whether they were improperly motivated in their placement of the Plan, and whether they unlawfully cut-back benefits through a retroactive amendment. The court also found certification appropriate under Rule 23(b)(2), stressing that the relief sought would apply to all class members, the material facts were largely uniform, and while the declaratory or injunctive relief would likely be a mere “prelude” to damages, that was not problematic since the damages would be “easily computed by objective standards.”  

Defendants argued that certification was inappropriate given the failure of class members to exhaust their administrative remedies. The court rejected this on multiple grounds, concluding that the fiduciary breach and Section 510 claims did not require exhaustion, the Plan itself did not mandate that workers exhaust an internal review process before filing suit, exhaustion would be futile given defendants’ application of a uniform interpretation that precluded grating the benefits, and unnamed class members should not be required to exhaust or should be given a flexible time frame in which to do so.

The court also rejected defendants’ “speculative defense” with respect to statutes of limitations, noting that the defendants failed to explain “with specificity, how statute of limitations issues would unwind the bundle of common issues” for the early retirement class. And even with respect to the optional retirement class, the court would simply be required to decide either one or two statute of limitations questions, thus bolstering commonality and adequacy rather than defeating it.

Finally, the court addressed and rejected defendants’ argument that typicality was defeated because one of the plaintiffs, Mr. Major, signed a release. Instead, because Mr. Benson has not signed a release, the court found the “mixed representatives typical of the mixed class they will represent,” which defendants say includes between 100 and 389 participants who have signed releases. Moreover, the court noted a number of reasons that led it to conclude that the releases were not likely to become a “major focus” of the litigation.

Thus, the court was satisfied that it was appropriate to certify two classes. First, it certified an “early retirement class” represented by Plaintiff Robert Cockerill consisting of “all Plan participants who were less than age 50, with at least 15 years of service under Title I of the Plan, and who were employed by Historical DuPont or any other participating employer of Title I of the Plan, and who continued to be employed post spin-off by New DuPont or one of its subsidiaries that did not participate in the Plan until they reached age 50, and beneficiaries and estates of such participants.”

Second, the court certified an “optional retirement class” represented by Plaintiffs Oliver Major and Derrell Benson, consisting of “all Plan participants who were over age 50, with at least 15 years of service under Title I of the Plan, and who were employed by Historical DuPont or any other participating employer of Title I of the Plan, and who continued to be employed post spin-off by New DuPont or one of its subsidiaries that did not participate in the Plan until they reached age 50, and beneficiaries and estates of such participants.” The court carved out from this second class “anyone who received or was eligible for unreduced Early Retirement Benefits…[and] whose Early Retirement Benefits, at spin-off or through present, would be equal to, or greater than their Optional Retirement Benefit.” 

The class is represented by Susan Meter and your editor Elizabeth Hopkins of Kantor & Kantor LLP, along with Edward Stone of Edward S. Stone Law P.C., and Daniel Feinberg and Nina Wasow of Feinberg Jackson Werthman & Wasow.

Next week, we will cover another important pension decision issued this week from the Second Circuit – Cunningham v. Cornell University – so stay tuned. In the meantime, we wish all of you a wonderful Thanksgiving with your families and friends.

Below is a summary of this past week’s notable ERISA decisions by subject matter and jurisdiction.

Breach of Fiduciary Duty

Second Circuit

Boyette v. Montefiore Med. Ctr., No. 22-cv-5280 (JGK), 2023 WL 7612391 (S.D.N.Y. Nov. 14, 2023) (Judge John G. Koeltl). Former employees of Montefiore Medical Center who are participants in its 403(b) retirement plan have sued Montefiore and the other plan fiduciaries under ERISA in this putative breach of fiduciary class action. Plaintiffs alleged in their complaint that the recordkeeping costs for the plan were much higher than those paid by similarly sized comparable peer plans contracting with the same and similar service providers. “From 2017 to 2020, the Plan’s recordkeeping cost per participant is alleged to have ranged from $136.51 to $230.25 with revenue sharing, and $136.51 to $172.70 without revenue sharing.” For comparison, plaintiffs contend that other plans with at least 15,000 participants and $300 million in assets had per-participant recordkeeping costs ranging from $23 to $30. In addition to their fee claims, plaintiffs also challenged the plan’s investments. First, they allege that the plan failed to identify and invest in lower-cost share classes of five funds in the plan. The participants maintain that the share classes chosen by the fiduciaries were the same in every respect other than their cost to these less expensive and available counterparts, and that defendants failed to prudently monitor the plan to invest the lowest-cost share classes for its funds. Second, plaintiffs allege that the plan retained high-cost and underperforming funds as investment options. They identified comparator funds in their complaint with superior returns and lower costs, and argued that prudent fiduciaries would have made themselves aware of these investment options and switched to them. Defendants moved to dismiss the complaint for lack of standing pursuant to Federal Rule of Civil Procedure 12(b)(1) and for failure to state a claim pursuant to Federal Rule of Civil Procedure 12(b)(6). The court granted the motion to dismiss in this order. “At the outset, the Court notes that it recently dismissed a substantially similar case alleging a breach of fiduciary duty of prudence in violation of ERISA.” This action, the court held, was not distinguishable from the one it recently dismissed, “and many of the reasons that required dismissal in [Singh v. Deloitte LLP, 650 F. Supp. 3d 259 (S.D.N.Y. 2023)] require dismissal of this case.” Like the Singh decision, the court ruled here that plaintiffs lacked Article III standing to bring claims related to the lower-cost share classes of the five individual funds at issue in which they did not invest. The court wrote, “plaintiffs lack standing with respect to their claims challenging the funds that charged excessive expense ratios, because plaintiffs did not invest in these funds.” The same was true for the underperforming funds as well, as the named plaintiffs did not personally invest in these options either and therefore could not show that they were harmed by their low returns and high costs. Moreover, the court concluded that plaintiffs could not assert their recordkeeping fee claims because they filed to plead the recordkeeping fees they individually paid each year. The court found that the complaint’s comparison between the average per-participant fee and reasonable fees charged by similarly sized plans did not satisfy Article III’s requirement of a cognizable injury. Thus the court dismissed all of plaintiffs’ claims, those based on fees and those based on funds, due to lack of standing. Although unnecessary, the decision then discussed why the court also would hold that plaintiffs failed to state their claims pursuant to Rule 12(b)(6). In addition to the injury-in-fact issues the court identified, it also stated that plaintiffs’ fee claims failed because they did not plausibly allege that the costs incurred “were excessive relative to the services rendered.” The court expressed that plaintiffs had the same problem with their share-class claims. “The existence of a cheaper fund does not mean that a particular fund is too expensive in the market generally or that it is otherwise an imprudent choice.” Ignoring the fact that plaintiffs’ complaint alleged the share-classes were identical in all ways other than cost, the court provided its own rationale for investing in the more expensive funds “the Plan received revenue sharing from four of the five more expensive class shares and…such proceeds were credited back to participants investing in those funds,” meaning “the plaintiffs received a benefit from the higher cost share classes.” Finally, the court stated that it would dismiss the underperforming fund claims because the complaint’s allegations about their poor results alone are insufficient to sufficiently state a claim for a fiduciary breach. Accordingly, the court expressed that it would dismiss the complaint based on both Rules 12(b)(1) and (b)(6), and granted defendants’ motion. However, dismissal was without prejudice, and the court held that plaintiffs may move for leave to file an amended complaint.

Fourth Circuit

Martone Constr. Mgmt. v. Thomas A. Barrett, Inc., No. DKC 23-450, 2023 WL 7489951 (D. Md. Nov. 13, 2023) (Judge Deborah K. Chasanow). As administrator of ERISA-governed defined benefit and 401(k) profit sharing plans, plaintiff Martone Construction Management, Inc., brought this ERISA breach of fiduciary duty action against the plans’ former service providers, defendants Thomas F. Barrett, Inc., National Employers Retirement Trust, Sandy Spring Bank, and Acorn Financial Advisory Services. In its complaint, Martone alleges that defendants breached their duties to the plan by (1) charging undisclosed investment fees without providing investment advisory services; (2) failing to follow Martone’s instructions with respect to the trading of plan assets; (3) improperly limiting the investment options available to the plan; (4) not following Martone’s instructions when it wished to change service providers; and (5) liquidating and transferring plan assets in ways not authorized by Martone and contrary to its instructions. As a result of these actions, plaintiff alleges that the plan incurred losses in the form of decreased value of plan assets and improper payments out of plan assets. In this action it seeks to remedy these financial harms. Martone asserted breach of fiduciary duty claims under ERISA, co-fiduciary liability claims, an equitable relief claim under ERISA Section 502(a)(3), and common law claims of breach of fiduciary duty, unjust enrichment, and negligence. Defendants moved to dismiss the action for failure to state a claim. Their motion was granted in part and denied in part. First, the court dismissed National Employers Retirement Trust as a defendant in this lawsuit because it is a trust, not a person or entity capable of being sued. However, all the ERISA claims against the remaining defendants were allowed to proceed past the pleadings. Accepting the allegations in the complaint as true, the court found that Martone properly alleged that defendants were functional fiduciaries under ERISA, that they breached their duties to the plan, and that those breaches caused losses to the plan. It also determined that defendants were subject to co-fiduciary duty for their participation in each other’s alleged breaches, and that Martone had not engaged in improper group pleading of the defendants. The court was also satisfied that each of the ERISA claims were unique and not duplicative of one another. With regard to the three common law claims, the court dismissed the claims for breach of fiduciary duty and negligence, concluding these two claims were alternative enforcement mechanisms to ERISA and therefore preempted by ERISA. However, the court found that the common law unjust enrichment claim did not relate to the ERISA plans but was instead alleging “that Martone conferred a benefit upon…Defendants for services [they] did not provide.” This claim was therefore not dismissed. Thus, most of plaintiff’s complaint was left intact following this decision, with the majority of its claims remaining in place.

Tenth Circuit

Jones v. Dish Network Corp., No. 22-cv-00167-CMA-STV, 2023 WL 7458377 (D. Colo. Nov. 6, 2023) (Magistrate Judge Scott T. Varholak). A group of former Dish Network Corporation employees who participate in its 401(k) plan have sued the plan’s fiduciaries for breaching their duties under ERISA in this putative class action. The court previously dismissed plaintiffs’ complaint without prejudice. Plaintiffs timely amended their complaint to add information about the fiduciaries’ conduct retaining a suite of Freedom Target Date Funds as the plan’s default investment option, which they maintain was an imprudent and disloyal action. In particular, plaintiffs outlined the ways in which the fiduciaries failed to follow the plan’s investment policy statement (“IPS”) with regard to the funds, which they argue were costly, risky, and significantly underperformed other available target date funds. They contended that the defendants engaged in a faulty monitoring process to oversee the default investment options and argued that had defendants complied with the process outlined in the IPS they would have replaced the funds and prevented the major losses the plan ultimately incurred. Defendants moved to dismiss the amended complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). In this report and recommendation, Magistrate Judge Varholak recommended that the court grant the motion to dismiss the duty of loyalty claim, but otherwise deny the motion to dismiss the claims of imprudence, failure to monitor, co-fiduciary breaches, and knowing breach of trust. The court agreed with plaintiffs that their amended complaint cured the deficiencies the court previously identified and demonstrated the ways in which defendants “ignored their own selected criteria for evaluating and monitoring the prudence of the Plan investments.” Despite the existence of the IPS, the amended complaint alleges that defendants did not follow the process it outlined to critically assess the challenged target date funds’ performance and that this procedural failure by defendants led to the imprudent retention of these funds as the plan’s default investments. Accordingly, viewing the complaint in the light most favorable to the participants, the Magistrate was satisfied that they stated their claims arising from the duty of prudence. However, Magistrate Varholak found that the amended complaint did not include any new factual allegations that defendants’ actions were self-serving and done for their own benefit. As a result, he recommended the court grant the motion to dismiss the breach of duty of loyalty claim. 

Disability Benefit Claims

Eighth Circuit

Cortez v. General Mills, No. 22-cv-1552 (ECT/JFD), 2023 WL 7489998 (D. Minn. Nov. 13, 2023) (Judge Eric C. Tostrud). Plaintiff Enrique Cortez filed a one-count complaint seeking to recover terminated long-term disability benefits pursuant to ERISA. Mr. Cortez began receiving benefits in 2017 under an ERISA-governed plan sponsored and administered by his former employer, defendant General Mills. Mr. Cortez received disability benefits for a combination of health conditions including back and leg pain, neuropathy, major depressive disorder, and cognitive conditions which were the result of side effects of his prescription medications. After paying benefits for approximately four years, the plan determined that Mr. Cortez’s physical and mental health conditions no longer disabled him from performing full-time work and therefore issued a decision denying benefits going forward. Mr. Cortez appealed internally. He filed this case following the appeal committee’s decision affirming the termination of benefits during the administrative process. Now the parties have cross-moved for judgment on the administrative record. Before the court could reach a conclusion on the benefits decision, it needed to resolve the parties’ dispute over the appropriate review standard. Mr. Cortez argued that de novo review should apply because General Mills failed to strictly adhere to the Department of Labor’s regulation requiring plans to issue benefit determinations within a 45-day deadline. The court disagreed with Mr. Cortez on this point. It stressed that the DOL’s regulation did not apply because Mr. Cortez began receiving disability benefits before April 1, 2018. Under the relevant case law, the court stated that it was irrelevant that the challenged termination of benefits at issue in this lawsuit occurred after the regulation’s effective date. Accordingly, it determined that the plan’s arbitrary and capricious review standard remained in effect regardless of the untimely benefit determination. Applying this deferential review standard, the court ruled that substantial evidence supported the decision to terminate the long-term disability benefits. It pointed to several strong pieces of evidence in the administrative record which supported the idea that Mr. Cortez could return to full-time work with his medical conditions, including the opinions of some of Mr. Cortez’s own treating physicians. Although the court acknowledged that the administrative record also included evidence supporting Mr. Cortez’s position that his health conditions were disabling, it held that this evidence did not demonstrate an abuse of discretion as it did not substantially undermine the credibility “of the evidence on which the Appeal Committee based its decision.” Furthermore, the court disagreed with Mr. Cortez that General Mills was required to show an improvement of his conditions from when it approved benefits to when it terminated them. As General Mills always operated under a degree of skepticism about whether to continue approving Mr. Cortez’s claim, the court stated that it was not unreasonable for it to terminate benefits when it was presented with significant new pieces of information in the medical records, even if the underlying health conditions remained fairly consistent. Finally, the court was unpersuaded that the Social Security Administration’s grant of disability benefits was proof that the committee’s decision to terminate benefits was an abuse of discretion. Based on the forgoing, the court entered judgment in favor of General Mills.

Ninth Circuit

Perez v. Unum Life Ins. Co. of Am., No. 22-16652, __ F. App’x __, 2023 WL 7675458 (9th Cir. Nov. 15, 2023) (Before Circuit Judges Graber, Paez, and Friedland). In a concise, unpublished, and unanimous decision, the Ninth Circuit affirmed judgment in favor of defendant Unum Life Insurance Company in this ERISA disability claim lawsuit. Plaintif-appellant Robert Perez’s long-term disability benefits were terminated after Unum concluded he was no longer totally disabled from performing any sedentary occupation. The district court found that Mr. Perez could not prove his entitlement to continued benefits as his musculoskeletal conditions had improved when Unum terminated the benefits, and because it agreed with Unum’s vocational expert that Mr. Perez could perform the sedentary occupations identified in the termination letter. On appeal Mr. Perez argued that the lower court had committed a clear error by allowing Unum to adopt new rationales to support its decision in litigation. The Ninth Circuit disagreed. “All of the challenged portions of the district court’s order reflect reasoning on which Unum relied in its denial letters.” It stated that Mr. Perez was not up against any rationales adopted or advanced only in litigation, and therefore would not overturn the decision on this basis. The court of appeals was also unwilling to adopt Mr. Perez’s argument in favor of adding on a contract term interpreting pre-disability earnings ability under a sliding definition based on the claimant’s “station in life.” Finally, the court concluded that policy at issue allowed the vocational expert to consider alternative occupations that require minimal on the job training. The Ninth Circuit declined to adopt Mr. Perez’s position that Unum could only consider jobs he could do right away without training. Thus, having considered all of Mr. Perez’s contentions on appeal and finding no basis to reverse the district court’s findings of fact, the Ninth Circuit affirmed. 

Discovery

Ninth Circuit

Lundstrom v. Young, No. 18cv2856-GPC (MSB), 2023 WL 7713579 (S.D. Cal. Nov. 15, 2023) (Magistrate Judge Michael S. Berg). Plaintiff Brian Lundstrom does not want his ex-wife to receive his pension benefits. For years he has sought and failed to undermine their Qualified Domestic Relations Order (“QDRO”). In this action he has sued his former employer, Ligand Pharmaceuticals Incorporated, and its 401(k) plan under ERISA in an attempt to keep the benefits for himself. He has three causes of action against Ligand. The first is a claim that Ligand has distributed the benefits in the plan account in violation of plan terms. The second is a claim for failure to promptly provide him with a copy of the plan’s procedures for determining the qualified status of domestic relations orders and failing to send written notice that his QDRO met the requirements under the plan and the Internal Revenue Code. Finally, Mr. Lundstrom asserts an anti-retaliation claim under Section 510 for retaliating against him for exercising his rights under ERISA. In this decision Magistrate Judge Berg ruled on a discovery dispute among the parties. Mr. Lundstrom moved to compel Ligand’s Chief People Officer, its General Counsel, and its person most knowledgeable to answer questions regarding email communications Ligand had with outside counsel related to Mr. Lundstrom’s QDRO. Ligand opposes, invoking attorney-client privilege. Defendants maintain that Ligand’s communications with outside counsel involved discussions over potential civil liability in the face of competing demands from Mr. Lundstrom and his ex-wife and that these emails are therefore privileged from discovery. The court agreed: “[T]he advice was given in anticipation of litigation and was not related to plan administration, so the communications are protected by the attorney-client privilege and not subject to the fiduciary exception.” Furthermore, the court agreed with Ligand that it was reasonable for it to “understand that ‘trouble was in the air,’” and that there was likely an imminent threat of litigation. In sum, the Magistrate concluded, “Ligand’s reasons for seeking legal advice on its own behalf were well-founded given Plaintiff’s statements, Plaintiff’s hiring outside counsel, and Ligand’s history of litigation involving Plaintiff and [his ex-wife].” Accordingly, Magistrate Judge Berg found that the communications were protected and thus denied Mr. Lundstrom’s motion to compel further deposition testimony regarding them.

Life Insurance & AD&D Benefit Claims

Eighth Circuit

Geiser v. Securian Life Ins. Co., No. 21-cv-2247 (WMW/DTS), 2023 WL 7923781 (D. Minn. Nov. 15, 2023) (Judge Wilhelmina M. Wright). On March 28, 2020, decedent Cynthia Litzau accessed her employer’s online portal and modified her beneficiary designations for life insurance benefits under an ERISA-governed group policy provided by defendant Securian Life Insurance Company. Ms. Litzau changed the designation from 100% of the benefits to her spouse, Timothy Litzau, to 50% going to her husband, 13% going to her daughter Selena Geiser, 13% going to her daughter Jennifer Heldt, and 12% each to two of her grandchildren. The story doesn’t end there though. A couple of months later, on May 12, 2020, Ms. Litzau revisited the online portal and reverted her designation back to restore her husband as the sole 100% beneficiary of the benefits. Thus, after Ms. Litzau died on May 23, 2020, Securian was informed by the employer that Mr. Litzau was the 100% beneficiary, and in accordance with that most recent beneficiary designation, Securian paid Mr. Litzau 100% of the life insurance benefits. In this action, Ms. Litzau’s daughters contest the last beneficiary designation and the payment of the life benefits to Timothy Litzau. They allege that Securian breached its fiduciary duties under ERISA. Securian moved for summary judgment in its favor. Its motion was granted in this order. The court found that there was no genuine issue of material fact that Ms. Litzau’s beneficiary designation changed on May 12, 2020 and that Securian properly paid Mr. Litzau the benefits based on the most recent beneficiary designation. “Securian did not breach a fiduciary duty by following the plan documents. Even if Plaintiff’s allegations as to Decedent’s intended beneficiaries were true, Securian would not have abused its discretion by paying Additional Life Benefits to Timothy Litzau, the named beneficiary on the plan documents. Pursuant to ERISA, Saurian must act in accordance with plan documents and instruments governing the plan.” Additionally, the court agreed with Securian that it did not have any control or discretionary authority or fiduciary function over the employer’s benefit portal and the beneficiary designations, meaning “Securian is not liable under ERISA for the alleged failure of the online portal to register Decedent’s intended changes to her beneficiary designations.” Finally, the court determined that plaintiffs’ allegations of fraud regarding the events surrounding the last beneficiary designation change were “too speculative and insufficient to meet the high threshold for reformation under ERISA.” Based on these findings, the court determined that summary judgment in favor of Securian was warranted for all claims and therefore granted its motion for judgment.

Pension Benefit Claims

Sixth Circuit

Gragg v. UPS Pension Plan, No. 2:20-cv-5708, 2023 WL 7525743 (S.D. Ohio Nov. 14, 2023) (Judge Algenon L. Marbley). Plaintiff Ralph Gragg worked for the company Overnite Transportation Co. from 1979 until it was purchased by United Parcel Service (“UPS”) in 2005. From 2005 until his retirement in 2010, Mr. Gragg worked for UPS. Following UPS’s acquisition of Overnite, and based on his positions at both companies, Mr. Gragg became a participant in two separate retirement plans and earned benefits under both plans. With his retirement approaching, Mr. Gragg reviewed and considered his election options under the plans. Based on the information he was provided, he ultimately selected the Social Security Leveling Option – Age 65 for both plans. In this action Mr. Gragg is challenging what he believes to be a miscalculation of his benefits for the options he selected. In essence, he is arguing that his monthly payments are improperly being reduced by twice the amount of his Social Security benefit, with each plan reducing his monthly benefit payments by the full amount of his Social Security retirement benefit. “Plaintiff alleges that Defendant miscalculated his benefits because it failed to consider, that although he was receiving his pension from two plans, he only received one Social Security retirement check.” In response, UPS maintains that Mr. Gragg’s “request is not permitted by law according to the Internal Revenue Code,” as the Internal Revenue Code prohibits any retirement benefit option being greater than the qualified joint and survivor annuity options. The parties cross-moved for judgment. The court wrote that it was “not convinced by [defendant’s] all-or-nothing approach,” and stressed that the “anti-cutback rule of ERISA prohibits Defendant from enforcing an interpretation of plan language that reduces that value of Plaintiff’s accrued benefit owing to his Overnite service.” It went on to state, “[t]echnical constructions of the plan’s language which defeat a reasonable expectation of coverage would run against the interests of justice, depriving the Plaintiff of the retirement benefits which he rightly earned.” That being said, the court also held that Mr. Gragg’s evidence was “not so overwhelming that a reasonable jury” could not rule against him, as UPS is correct that Mr. Gragg’s interpretation of the plan language would violate the Internal Revenue Code. Given the strengths and weaknesses of each party’s arguments and the weird situation presented here, the court denied both motions for judgment. But the court concluded that Mr. Gragg should not be left without any remedy. It found the proper remedy here to be to order UPS to recalculate Mr. Gragg’s post-65 benefit amount “in a manner that prorates his Social Security benefit amount, while taking care not to exceed the Qualified Joint & Survivor Annuity options under 26 C.F.R. §1.401(a)-11(b)(2).” Accordingly, this resolution was the creative solution the court arrived at.

Radmilovich v. Unum Life Ins. Co. of Am., No. SA CV 22-00181-DOC-KES, __ F. Supp. 3d __, 2023 WL 7457118 (C.D. Cal. Nov. 7, 2023) (Judge David O. Carter)

In selecting this week’s notable decision, we are admittedly engaging in some light self-promotion, as Kantor & Kantor prevailed in this published district court decision on behalf of a client seeking long-term disability benefits.

The plaintiff was David Radmilovich, an industrial engineer who suffered a cardiac arrest in 2016 at the age of 53. Paramedics who responded performed lifesaving CPR after discovering he had no pulse, no blood pressure, and was not breathing. While recovering in the hospital, his cardiologist determined he had multilevel coronary artery disease.

Unsurprisingly, this traumatic event had lasting health consequences. Mr. Radmilovich underwent coronary artery bypass surgery and could not return to work until 2017. His ability to work was compromised, as he suffered from heart palpitations, dizziness, shortness of breath, and chest pain. Mr. Radmilovich’s cardiologist referred him for a neuropsychological evaluation (NPE), which also determined he was suffering from a mild neurocognitive disorder and a somatic symptom disorder. His symptoms continued and he was eventually forced to stop working.

Mr. Radmilovich submitted a claim for benefits to the insurer of his employer’s group long-term disability employee benefit plan, defendant Unum Life Insurance Company of America. Unum paid benefits for just over a year, but terminated them in October of 2019, concluding that Mr. Radmilovich had “above average exercise capacity,” there was “no clear evidence of cognitive impairment,” and there was no behavioral impairment.

Mr. Radmilovich appealed, submitting an updated NPE and an independent cardiology evaluation, among other evidence. The NPE diagnosed Mr. Radmilovich with major neurocognitive disorder, tracing his problems to his cardiac arrest which had deprived his brain of oxygen. The cardiologist determined that Mr. Radmilovich was suffering from ongoing coronary microvascular disease. Both agreed he was disabled. Unum remained unconvinced, however, and upheld its termination. As a result, Mr. Radmilovich filed this action.

The district court found in favor of Mr. Radmilovich under de novo review. In doing so, it touched on a number of issues that commonly arise in long-term disability cases. First, the court gave the opinions of Mr. Radmilovich’s doctors more weight than those of Unum’s reviewing physicians, who had only conducted “paper reviews” and did not examine him in person. Specifically, the court credited reports from Mr. Radmilovich’s treating physicians that confirmed his symptoms and explained how they were a result of his 2016 cardiac arrest.

Second, the court criticized Unum’s use of “a generic list of occupational activities” in determining whether Mr. Radmilovich was disabled, instead of considering “the specific requirements of Mr. Radmilovich’s job.” In doing so, the court ruled that Unum did not abide by the policy’s definition of disability and Ninth Circuit case law which holds that “insurers must consider the insured’s actual job activities.” (The two cases cited by the court for this proposition were both Kantor & Kantor victories: Salz v. Standard Ins. Co., 380 F. App’x 723 (9th Cir. 2010), and Kay v. Hartford Life & Accident Ins. Co., No. 21-55463, 2022 WL 4363444 (9th Cir. Sept. 21, 2022).)

Third, the court agreed with Mr. Radmilovich that it was permitted to consider evidence that was acquired after Unum terminated his benefits, and also agreed that just because his doctors’ diagnoses had changed over time that did not make them necessarily less credible.

Fourth, the court ruled that Unum did not adequately take all of Mr. Radmilovich’s conditions into consideration. The court noted that it was not prepared to rule that Mr. Radmilovich had “met his burden to prove that he was disabled from just his cardiac condition or just his cognitive impairments,” but it was convinced that the combined conditions rendered him disabled and entitled to benefits.

As a result, the court concluded that Mr. Radmilovich was entitled to benefits during the initial two-year “own occupation” time period, and remanded to Unum to determine whether he was entitled to benefits past that period, and whether he was entitled to a waiver of premiums on his life insurance benefits due to his disability.

Mr. Radmilovich was represented by Glenn R. Kantor, Sally Mermelstein, and Rhonda Harris Buckner of Kantor & Kantor LLP.

Below is a summary of this past week’s notable ERISA decisions by subject matter and jurisdiction.

Attorneys’ Fees

Ninth Circuit

Neumiller v. Hartford Life & Accident Ins. Co., No. C22-0610 TSZ, 2023 WL 7280906 (W.D. Wash. Nov. 3, 2023) (Judge Thomas S. Zilly). Plaintiff Julie Neumiller commenced this ERISA action against Hartford Life & Accident Insurance Company to challenge its termination of her long-term disability benefits. Ms. Neumiller’s motion for judgment on the administrative record was denied in the district court. It entered judgment instead in favor of Hartford. Ms. Neumiller subsequently appealed that adverse ruling and found success in the Ninth Circuit. The court of appeals held that Hartford had failed to correctly prorate Ms. Neumiller’s trimester bonus when calculating her current monthly earnings. Based on this finding, the Ninth Circuit vacated the lower court’s judgment and remanded for further development of the administrative record. Back in district court the Ninth Circuit’s instructions were relayed to Hartford, as the district court remanded the matter to the insurer to develop the record to include more information regarding the trimester bonuses and to revise its benefits decision consistent with this updated information and the position of the Ninth Circuit. Before Hartford decided the remand, Ms. Neumiller moved for an award of attorney’s fees and costs pursuant to ERISA’s fee statute, Section 502(g)(1). Hartford opposed the motion. It argued that Ms. Neumiller’s success was purely procedural. The court disagreed. Relying on well-developed case law, it found that remand to an insurance company to conduct further administrative proceedings is a significant degree of success on the merits to make an ERISA plaintiff eligible for an award of fees. Moreover, the court agreed with Ms. Neumiller that her success warranted a fee award, as it will serve to deter Hartford from violating its ERISA obligations going forward and may discourage it “from prioritizing its own interests over the interests of plan beneficiaries.” Further, the court wrote that by bringing this action, “Plaintiff has benefited other plan participants by clarifying how an ambiguous plan provision is to be interpreted.” Thus, the court found that the relevant factors supported an award of fees and costs to Ms. Neumiller. Ms. Neumiller moved for an award of $42,000 in attorney’s fees, based on an hourly rate of $600 per hour for her counsel. Hartford did not argue in its opposition to the fee motion that the hours expended, or the attorney’s hourly rate, were unreasonable. And the court did not view them as such. Accordingly, Ms. Neumiller was awarded her full requested fee award. She was likewise awarded $844.40 in costs. Thus, plaintiff’s motion was granted in an entirely unaltered form, and Hartford was ordered to pay a total of $42,844.40 to Ms. Neumiller.

Breach of Fiduciary Duty

Ninth Circuit

The Bd. of Trs. for the Alaska Carpenters Defined Contribution Tr. Fund v. Principal Life Ins. Co., No. 22-cv-01337, 2023 WL 7280748 (W.D. Wash. Nov. 3, 2023) (Judge Jamal N. Whitehead). In this action the Board of Trustees for the Alaska Carpenters Defined Contribution Trust Fund has sued its former third-party administrator, Principal Life Insurance Company, for breaching its fiduciary duties under ERISA and breaching its contract with the Board. In essence, the trustees allege that Principal, which had control over fund assets, “used its discretion to unilaterally withdraw fees inconsistent with the ‘understanding and practice’ involving fees and representations made to the Board about the same.” Thus, alleging that Principal took more than its fair, and contractually agreed upon, share of fees, the Board maintains that its service provider was in violation of both ERISA and state contract laws. Principal moved to dismiss the complaint for failure to state a claim. The court denied its motion, finding that plaintiff plausibly alleged its ERISA and breach of contract claims. The court was satisfied that the complaint plausibly alleges that Principal was functioning in its fiduciary capacity at the time of the actions that are the subject of this lawsuit. Specifically, the court stated that under Ninth Circuit precedent on the topic, plaintiffs who allege that ERISA plan service providers are taking more from plan funds than they are entitled to “plausibly allege a fiduciary relationship.” As for the breach of contract claim, the court held that the complaint cites the service agreement as the contract creating and outlining Principal’s duties, and also cites the specific duties that the Board contends Principal breached, which caused the damages at issue. For these reasons, Principal’s motion to dismiss was denied.

Eleventh Circuit

Foughty v. Cleaver-Brooks, Inc., No. 1:23-CV-3074-TWT, 2023 WL 7287220 (N.D. Ga. Nov. 3, 2023) (Judge Thomas W. Thrash, Jr.). Plaintiff Pamela Foughty’s late husband, decedent William Foughty, was an employee of defendant Cleaver-Brooks, Inc. Sadly, Mr. Foughty was diagnosed with brain cancer in the spring of 2020. Following his diagnosis, the Foughtys “worked diligently to ensure his life insurance policy would remain active through the time of his death.” Nevertheless, after Mr. Foughty’s death, Ms. Foughty’s claim for benefits was denied by life insurer Reliance Standard. This action arises from that denial. After Reliance upheld its decision during the internal appeals process, Ms. Foughty sued the insurer. That case was settled for the full benefits amount plus interest. In this lawsuit, Ms. Foughty has sued Cleaver-Brooks for its role in providing false and misleading information which resulted in the loss of life insurance coverage. Ms. Foughty alleges a single claim for breach of fiduciary duty under Section 502(a)(3) of ERISA. Cleaver-Brooks moved to dismiss the complaint for failure to state a claim. It argued that it did not breach any duties owed to the family, that Ms. Foughty is improperly seeking compensatory damages, and that res judicata bars her claim. Ms. Foughty responded that defendant plausibly breached its fiduciary duties and that she is entitled to make-whole compensation under the theory of equitable surcharge. Further, Ms. Foughty maintains that her settlement with Reliance Standard carved out and preserved her claims against Cleaver-Brooks, meaning res judicata does not bar her claim. As a preliminary matter, the court identified defendant’s first argument – that it didn’t breach any fiduciary duty owed to Ms. Foughty – as a merits dispute “inappropriate for consideration at the motion to dismiss stage.” However, the court considered defendant’s arguments regarding equitable surcharge and res judicata. First, it held that Ms. Foughty does not have an adequate remedy at law under Section 502(a)(1)(B), because the plan was fully insured meaning “its recourse to recover benefits due under the plan was against Reliance Standard, not the Defendant.” As to whether to allow equitable surcharge as a remedy in this case where Ms. Foughty is bringing a claim for breach of fiduciary duty against the employer after first proceeding against the insurer, the court stated that it could find “no legal authority prohibiting such a proceeding. Absent such authority, the Court cannot conclude that the Plaintiff’s elected procedure bars her § 502(a)(3) claim against the Defendant.” With regard to res judicata, the court agreed with Ms. Foughty that privity does not exist between Cleaver-Brooks and Reliance Standard in the prior suit. Thus, the court held that res judicata does not bar the breach of fiduciary duty claim in this action. Accordingly, the court denied the motion to dismiss and allowed Ms. Foughty to proceed with her Section 502(a)(3) claim against the employer.

Class Actions

Ninth Circuit

Kazda v. Aetna Life Ins. Co., No. 19-cv-02512-WHO, 2023 WL 7305038 (N.D. Cal. Nov. 6, 2023) (Judge William H. Orrick). In this certified class action, a group of insured participants of EIRSA-governed healthcare plans administered by defendant Aetna Life Insurance Company are challenging Aetna’s use of clinical policies to systematically deny all claims for liposuction surgery for the treatment for the disease lipedema as cosmetic. Lipedema is a rare, painful, and progressive disease involving an abnormal buildup of fat tissue. Left untreated lipedema can lead to immobility. In their action, the class is alleging that Aetna’s policies categorically considered suction lipectomy to be a cosmetic procedure and that claims for the surgery were denied on this single basis thanks to those internal clinical policies. They further maintain that Aetna’s categorization of their claims as “cosmetic” is in direct conflict with the plans’ definitions of cosmetic procedures – surgeries intended to improve appearance rather than treat serious symptoms associated with diseases. Based on this theory of the case, the class brings two claims against Aetna – a claim for denial of benefits and clarification of rights under Section 502(a)(1)(B), and a claim for breach of fiduciary duty under Section 502(a)(3). Before the court were two motions. First, Aetna moved to decertify the class based on the Ninth Circuit’s rulings in the Wit v. United Behavioral Health action. Second, plaintiff Michala Kazda moved for summary judgment. In this decision the court denied both motions. Beginning with the motion to decertify, the court held that Wit II did not mean what Aetna was arguing it meant. Rather than a categorical rejection of reprocessing as a class remedy, the court wrote that Wit II clarifies “that reprocessing may be an appropriate remedy where an administrator has applied the wrong standard, and the claimant could have been prejudiced by the application of that standard.” The court stated that it had already found the class “made a showing at least for the purposes of class certification, that application of the wrong standards (here, Aetna’s CPBs) could have prejudged them.” This, the court held, “meets the minimum requirements for reprocessing,” and is common among all of the members of the class. Furthermore, the court emphasized that plaintiffs are not required to show entitlement to a positive benefits determination under Wit II, only that remand for reprocessing would not be futile. Finally, the court allowed plaintiffs to proceed with simultaneous claims under Sections 502(a)(1)(B), and (a)(3) because it continued to hold, as it did when it certified the class, that the remedies the class is seeking under each subsection are unique, available, and appropriate. Accordingly, the court found that nothing in Wit II requires or even supports decertification of the class. The decision then switched gears to analyze plaintiff’s motion for summary judgment. That motion too was denied. The court identified several issues of disputed facts material to both the benefit claim and the fiduciary breach claim. These issues included a material factual dispute over whether Aetna categorically denied claims for lipedema surgery as cosmetic based on the policies or whether the insurer individually reviewed claims for benefits to determine medical necessity. Aetna also offered evidence that cut against the complaint’s allegations of breaches of fiduciary duties. The court therefore held that undisputed evidence did not prove the class’ theory of the case and as such determined that an award of summary judgment to the claimants was inappropriate.

Disability Benefit Claims

Third Circuit

Patrick v. Reliance Standard Life Ins. Co., No. 21-1681, __ F. App’x __, 2023 WL 7381460 (3d Cir. Nov. 8, 2023) (Before Circuit Judges Restrepo, McKee, and Rendell). As you may have read above in our notable decision, in disability cases it is not uncommon for insurance companies to be somewhat creative with their classification of a claimant’s job title. Nevertheless, this case is quite an audacious and brazen example of a job reclassification even by the typical standards. Plaintiff Amy Patrick, M.D. is a gastroenterologist. Defendant Reliance Standard Life Insurance Company recognized as much during the ten years when it paid her long-term disability benefits. However, this changed when Reliance terminated Dr. Patrick’s benefits. “In 2019, notwithstanding Reliance’s having paid her benefits for a decade based on her inability to perform her duties as a Gastroenterologist, Reliance determined that Dr. Patrick was no longer entitled to benefits because her disability did not prevent her from performing the regular duties of an Internal Medicine Specialist.” Although the digestive system is internal, only AI would understand a GI doctor to be an internal medicine doctor. The two fields of medicine are functionally different. As a gastroenterologist Dr. Patrick was required to routinely perform GI procedures, including coloscopies and endoscopies, something she and her healthcare providers agree she is unable to safely and effectively do as she does not have full use of her right shoulder. Perhaps unsurprisingly then, the district court concluded that this behavior was an abuse of discretion and awarded benefits to Dr. Patrick. Agreeing with the lower court, the Third Circuit upheld its decision in this short unpublished order. The appeals court concurred with the district court that Reliance’s characterization of Dr. Patrick as an internal medicine specialist was not reasonable and “contrary to the plan’s plain language.” The Third Circuit agreed with the district court that “the record is replete with evidence that Dr. Patrick is a gastroenterologist: Dr. Patrick’s training, employment history, board certification, and even Reliance’s records of Dr. Patrick’s disability support the finding that the occupation she routinely performed when her Total Disability began was that of a Gastroenterologist. Indeed, at the time Reliance began paying Dr. Patrick benefits, she was not even board-certified to practice internal medicine.” Thus, the court rejected Reliance’s “ridiculous” position “that Gastroenterologist is not an occupation,” and therefore affirmed the holdings of the lower court, including its award of fees and costs.

Sixth Circuit

Olah v. Unum Life Ins. Co., No. 1:19-CV-96-KAC-CHS, 2023 WL 7305033 (E.D. Tenn. Nov. 6, 2023) (Judge Katherine A. Crytzer). Plaintiff Lori Olah commenced this action in 2019 to challenge Unum Life Insurance Company’s termination of her long-term disability and life insurance without premiums benefits under ERISA. Ms. Olah began receiving disability and no-premium life insurance benefits in 2017 following a spinal surgery she underwent to correct a pinched nerve root located in her lower back. Unum approved and paid Ms. Olah’s claim for benefits for one year following the surgery, at which time it terminated the benefits, concluding that she had been given an adequate amount of time for the nerve damage to heal. Unum’s reviewing doctors determined that Ms. Olah was exhibiting consistent signs of improved health and could return to sedentary work. Ms. Olah saw things differently. She maintained that she was continuing to experience debilitating back pain, stated that she required the use of a cane to walk, and pointed out that her orthopedic surgeon had diagnosed her with “moderately severe degenerative disc disease.” The parties filed cross-motions for judgment on the administrative record. Magistrate Judge Christopher H. Steger issued a report and recommendation recommending the court enter judgment in favor of Unum. Ms. Olah objected to the report. She argued that the Magistrate Judge erroneously permitted Unum to consider evidence of medical improvement which occurred while it was still approving her benefits, that the Magistrate’s report improperly cherry-picked evidence from Unum’s reviewers rather than considering the evidence of her treating healthcare providers, and that the report failed to adequately consider the conflict of interest that Unum’s reviewing doctors and claims handlers were operating under. In this decision, the court overruled Ms. Olah’s three objections and adopted the Magistrate’s report in full. To begin, the court held that Unum was entitled to consider the entire medical record, including evidence of medical improvement during the period in which benefits were approved. The court also held that Unum’s decision to rely on its own doctor’s opinions without an in-person exam of Ms. Olah was not on its own arbitrary or capricious. As for Ms. Olah’s argument that Unum and the report cherry-picked evidence in the record unfavorable to her, the court found that it was not an abuse of discretion on Unum’s part nor an error on the part of the report to credit one piece of conflicting evidence over another. Finally, with regard to Unum’s conflict of interest, the court found that Ms. Olah’s arguments failed because she could not produce any evidence that the conflicts Unum, its claims director, and its reviewing physicians were operating under “affected the plan administrator’s decision to deny her specific claim.” For these reasons, the court stated that it could not conclude the denial of Ms. Olah’s benefit claims was “anything other than a deliberate, principled reasoning process and supported by substantial evidence.” Accordingly, Unum’s motion for judgment was granted and Ms. Olah’s motion for judgment was denied.

Discovery

Fifth Circuit

Pedersen v. Kinder Morgan, Inc., No. 4:21-CV-3590, 2023 WL 7284177 (S.D. Tex. Nov. 2, 2023) (Magistrate Judge Dena Hanovice Palermo). In this pension benefits action, plan participants have sued the Kinder Morgan, Inc. cash balance plan and its fiduciaries asserting six separate claims under ERISA Sections 502(a)(1)(B) and (a)(3) for miscalculating early retirement benefits, failing to follow claims procedure regulations, violating ERISA’s anti-cutback provisions, using outdated mortality tables and interest rates, and for having plan language that is ambiguous and not understood by the average participant. Defendants previously tried and failed to limit the scope of plaintiffs’ action only to claims asserted under Section 502(a)(1)(B), “keen to prevent plaintiffs from bringing claims under Section 502(a)(3)…[to] severely limit discovery.” District Judge Ellison permitted four of the six claims to proceed under Section 502(a)(3), and therefore incorporated its less restrictive discovery procedures. The court then granted each party the ability to take 10 depositions each. Now defendants have moved for a protective order preventing plaintiffs from taking three of those ten depositions. The court denied the motions in this order, finding defendants failed to establish good cause for a protective order. It held that each of the three witnesses – the counsel to the plan, Ms. Bethany Bacci, and two members of the pension benefits team (Ms. Norma Ortega and Mr. Eddie Ammons) – possess unique information relevant to plaintiffs’ claims asserted under both subsections of ERISA. The court wrote that the record demonstrates that the three individuals have information and knowledge relevant to obtain discovery on the Crosby exceptions for claims asserted under Section 502(a)(1)(B), and that they further possess knowledge relevant to the claims brought under Section 502(a)(3) “which are not subject to ERISA’s narrow discovery, but rather are governed by Rule 26.” Moreover, the court was not convinced that the depositions would be duplicative of one another. Finally, the court did not require plaintiffs to submit a list of topics before deposing the individuals nor limit the duration of the depositions, as defendants had requested. Instead, the court allowed plaintiffs to depose Ms. Bacci, Ms. Ortega, and Mr. Ammons, and ask them questions relevant to the subjects of their claims, given that these “witnesses have a considerable amount of information and knowledge about which they may be deposed.”

Pedersen v. Kinder Morgan, Inc., No. 4:21-CV-3590, 2023 WL 7428865 (S.D. Tex. Nov. 9, 2023) (Magistrate Judge Dena Hanovice Palermo). Magistrate Judge Dena Hanovice Palermo wasn’t quite done ruling on discovery disputes in the Pederson action this week. In this second decision, the court weighed in on plaintiffs’ motion to apply the fiduciary exception to the attorney-client privilege with regard to communications and documents related to the plan’s administration. After examining the withheld documents during an in-camera review and analyzing the parties’ briefing and the relevant case law, the court concluded “that these documents are protected by attorney-client and work product privileges, and therefore Plaintiffs’ motion is denied.” The court stated that while the documents at issue do mention the plan beneficiaries, it emphasized that they do not “discuss or decide the merits of their pending claims and/or appeals and [don’t] direct the fiduciary committee to act on those claims.” The court ultimately disagreed with plaintiffs that the documents contained legal advice related to plan administration making them discoverable under the fiduciary exception. Instead, the court concluded that the withheld documents were privileged because the plan was receiving legal advice about the risks of potential litigation between it and its beneficiaries. Thus, as the documents analyze legal risks of potential litigation and discuss legal arguments and strategies for the plan, the court found that they were protected under the attorney-client privilege and work-product doctrine, not subject to the fiduciary exception, and thus protected from disclosure. Plaintiffs’ motion was accordingly denied.

Ninth Circuit

Schoenberger v. Securian Life Ins. Co., No. 2:23-CV-00096-LK, 2023 WL 7317199 (W.D. Wash. Nov. 2, 2023) (Judge Lauren King). Plaintiff Amelita Schoenberger brings this ERISA action seeking accidental death and dismemberment benefits that were denied by defendant Securian Life Insurance Company following the death of her husband. Ms. Schoenberger moved to conduct limited discovery regarding the disclosure of redacted claim file documents which she maintains are part of the administrative record and were improperly withheld pursuant to attorney-client and work-product privileges. Ms. Schoenberger contends that these file entries are discoverable under the fiduciary exception and that they therefore are improperly being withheld on the basis of privilege. Therefore, she moved for the court to order production of these documents and their redacted information. Securian opposed Ms. Schonberger’s motion. It argued that she did not comply with the Federal Rules of Civil Procedure because she did not serve discovery requests for production after obtaining leave to conduct discovery. In response, Ms. Schonberger stated that she was following the court’s method for resolving the discovery dispute as described in the joint status report. The court rejected this argument. “First, the Court does not entertain requests for relief in a Joint Status Report.” It stated that it had no intention of circumventing procedural requirements. Therefore, the court held that Ms. Schonberger was not exempted “from the standard discovery procedures applicable to compelling disclosure,” and her request for production of documents was accordingly determined to be procedurally improper. As a result, the court denied Ms. Schonberger’s limited discovery motion and cautioned her to comply with the Federal Rules of Civil Procedure going forward. However, the court did say, “to the extent the redacted information falls within the definition of ‘relevant’ documents, records, or information…Securian must comply with Rule 26(b)(5) by supplying Plaintiff with a privilege log.”

ERISA Preemption

First Circuit

Cannon v. Blue Cross & Blue Shield of Mass., No. 23-cv-10950-DJC, 2023 WL 7332297 (D. Mass. Nov. 7, 2023) (Judge Denise J. Casper). Plaintiff Scott Cannon, individually and as representative of the estate of Blaise Cannon, sued Blue Cross and Blue Shield of Massachusetts, Inc. in state court alleging six state law causes of action arising from Blue Cross’s denial of coverage for a Wixela Inhub inhaler to treat Blaise’s asthma. Without this inhaler, Blaise died due to complications related to his asthma. Blue Cross removed the action to federal court. It then moved to dismiss the complaint, arguing that the state law claims are preempted by ERISA and that Mr. Cannon has failed to state a claim under ERISA. Blue Cross attached several documents and exhibits to its motion to dismiss, including what it purports is the governing healthcare policy. However, Mr. Cannon questioned the completeness and authenticity of the documents Blue Cross submitted. Because the court could not say that the submitted documents were indisputably authentic, it denied the motion to dismiss without prejudice. “Had BCBS submitted an affidavit or declaration explaining the significance of the proffered policy documents and verifying they concerned the health insurance policy through which Blaise sought coverage for the Wixela Inhub inhaler, the Court may have considered the exhibits and reached the ERISA preemption arguments raised by BCBS’s motion to dismiss. However, in light of the parties’ submissions to date, the Court is unable to do so.” Nevertheless, resolution of the ERISA preemption issue remains important. Accordingly, the court ordered the parties to conduct limited discovery on matters bearing upon the issue and then to file summary judgment motions on ERISA preemption, at which point it will address and rule on whether ERISA governs the policy at issue and if so, whether Mr. Cannon can proceed with claims under ERISA.

Medical Benefit Claims

Tenth Circuit

Robert B. v. Premera Blue Cross, No. 1:20-cv-00187-DBB-CMR, 2023 WL 7282726 (D. Utah Nov. 3, 2023) (Judge David Barlow). Robert B., individually and on behalf of his son, C.B., brought this two-count ERISA action against Premera Blue Cross to challenge its denial of C.B.’s one-year long stay at a psychiatric residential treatment center. Robert B. alleges in his complaint that Premera’s denial violated ERISA by denying the family a full and fair review, incorrectly denying a benefit claim the family was entitled to under the terms of the plan, and for violating the Mental Health Parity and Addiction Equity Act by making coverage conditions for mental health residential treatment more onerous than analogs coverage for other types of medical and surgical care. The parties cross-moved for summary judgment. In this decision the court granted summary judgment in favor of plaintiff on his Section 502(a)(1)(B) benefit claim, remanded to Premera for reconsideration and a full and fair review, and granted judgment to Premera on the Parity Act violation claim. To begin, the court agreed with Robert B. that Premera entirely ignored evidence of suicidal ideation present in the medical record and that this flagrant disregard of a key qualifying symptom for residential treatment coverage under the relevant criteria was not a full and fair review of either the medical records or the claim for benefits. Moreover, the court found that Premera wholly ignored the opinions of C.B.’s treating healthcare professionals, thereby shutting its eyes to readily available and relevant medical information. The court wrote that “other than listing the letters as received or reviewed, none of the denial or review correspondence substantively addressed the treaters’ opinions. They do not discuss or reference the opinions whatsoever, leaving both the beneficiary and the court with no way of discerning whether they actually were engaged with substantively at all. The denials are simply devoid of what weight, if any, Premera accorded these opinions.” Such a lack of substantive engagement with relevant medical information was found by the court to fall short of a meaningful dialogue required under ERISA. Accordingly, the court agreed with plaintiff that Premera had acted arbitrarily and capriciously in denying the benefit claims. However, rather than award benefits, the court determined that the proper recourse was to remand to Premera for a full and fair review. It felt that this remedy was appropriate given Premera’s procedural failings and because the court could not say that the record clearly shows that plaintiff is entitled to benefits for the entire year-long stay at the facility. Moving to the Parity Act violation, the court drew a different conclusion, far less favorable to Robert B. He was alleging that the plan applied more restrictive criteria for mental health residential treatment centers than skilled nursing facilities including requiring more serious and acute psychiatric symptoms and by not factoring in the risk of decline or relapse if a patient is discharged. However, the court found that separate was not inherently unequal in these circumstances and simply pointing out differences between medical/surgical care and mental healthcare is insufficient to prevail on a Parity Act violation claim. Finding that Robert B. had not shown how the limitations for mental healthcare were more restrictive than the limitations for other types of care, the court granted summary judgment to Premera on the Parity Act claim.

Ninth Circuit

The Regents of the Univ. of Cal. v. The Chefs Warehouse, Inc., No. 2:23-cv-00676-KJM-CKD, 2023 WL 7284799 (E.D. Cal. Oct. 31, 2023) (Judge Kimberly J. Mueller). Is the Affordable Care Act (“ACA”) a misnomer? This decision from the Eastern District of California suggests it may be, after a patient insured under a self-funded, self-insured group health plan is now on the hook for nearly half a million dollars’ worth of health care for an inpatient hospital stay and outpatient chemotherapy treatment at the UC Davis Medical Center. In this order the court ruled that hospital had not plausibly alleged that the plan, The Chef’s Warehouse, Inc. Employee Benefit Plan, was in violation of ERISA or the ACA despite leaving the patient with bills far exceeding the plan’s own $3,600 out-of-pocket expenses limit and the $8,550 limit on out-of-pocket expenses in the ACA. Thus, the court granted the plan’s motion to dismiss the hospital’s complaint for failure to state a claim. The court stressed that the hospital was an out-of-network provider, meaning the plan was not barred under the ACA from requiring its participants to pay “any balance bills from outside the plan’s network, and the costs of any services the plan does not cover, regardless of the $8,550 limit.” This was so even though the plan at issue does not have a single hospital in network. Although the court acknowledged the language of the ACA is faulty and problematic, creating quite the loophole to its cost-sharing rules, the end result was this: “a plan can saddle a patient with the balance of a provider’s bill if the provider is not in the plan’s network.” And although the plan did not have a single hospital in network, the court found that the complaint did not allege that the plan participant’s only choice was to seek treatment from a hospital rather than an in-network provider. Without allegations that the patient had no choice but to seek care at a hospital, that the care she needed was practically unavailable in-network, and the plan’s price limits are not accepted by any provider, the court found that plaintiff’s theory of the case failed on its merits. “Nor has the hospital shown plans must include hospitals in their networks.” Shocking as these conclusions may sound, this decision is not an outlier. Other courts have drawn similar conclusions both regarding balanced out-of-network bills and inadequate healthcare networks. These cases were cited by the court in this decision as evidence that its hands were tied regardless of the absurdity of the results which appear on their face entirely inconsistent with the goals of affordable healthcare. Whether the hospital will be able to replead its two ERISA claims to convince the court that the plan at issue is akin to the junk insurance policies banned by Congress in the ACA, and by extension that its theories of the case are plausible under the terms of the ACA, remains an open question. However, the court dismissed the case without prejudice, meaning the provider will at least have the opportunity to attempt to do so.

Pension Benefit Claims

Ninth Circuit

Schmidt v. Emp. Deferred Comp. Agreement, No. CV-22-01464-PHX-ROS, 2023 WL 7413667 (D. Ariz. Nov. 9, 2023) (Judge Roslyn O. Silver). After her husband’s death, plaintiff Patricia Schmidt discovered a copy of a top hat plan in her home and subsequently sent a written demand for benefits under the plan. Her husband’s corporation, Temprite Co., adopted the position that this plan did not exist. Frustrated in her attempt to receive the monthly benefits she believed she was entitled to, Ms. Schmidt brought this ERISA lawsuit. The parties have cross-moved for summary judgment. There was no dispute that, if the plan is in place, Ms. Schmidt is entitled to benefits. The dispute instead is whether the plan was adopted and whether it remains in effect or was ever abandoned, rescinded, or replaced by a 2010 stock agreement. The court concluded in its decision here that the “record viewed in the light most favorable to Temprite establishes the top hat plan was validly adopted and never replaced.” In particular the court emphasized that the plan fiduciaries sent a letter to the Department of Labor to inform the agency of the plan’s creation and that it was in effect and intended to be a plan under ERISA. The court wrote that it was “not possible to read Brown’s letter [to the DOL] and conclude Brown wished to repudiate the top hat plan. To the extent necessary, Brown’s actions were sufficient to ratify adoption of the top hat plan.” In addition, the court held that the stock agreement in no way abandoned or replaced the top hat plan, finding “the undisputed evidence establishes the 2010 agreement was not intended to impact the top hat plan.” Based on the foregoing, the court determined that the plan was validly executed and remains enforceable today and therefore granted summary judgment in favor of Ms. Schmidt.

Plan Status

Ninth Circuit

Steigleman v. Symetra Life Ins. Co., No. CV-19-08060-PCT-ROS, 2023 WL 7413668 (D. Ariz. Nov. 9, 2023) (Judge Roslyn O. Silver). Plaintiff Jill M. Steigleman sued Symetra Life Insurance Company under state law to reinstate terminated long-term disability benefits. She stated in her action that she does not wish to pursue any ERISA-based claims, and that she does not believe the plan at issue, established in connection with her insurance agency, the Steigleman Insurance Agency, was governed by ERISA. In this decision, the court concluded that the disability coverage was part of an employee welfare benefit plan governed by ERISA and entered judgment in favor of Symetra. The court found that Ms. Steigleman’s agency always had employees and that it offered those employees benefit packages, including healthcare and disability benefits, that required an ongoing administrative scheme and discretionary decision making. Furthermore, the agency paid 100% of its employees’ premiums for certain coverage options, meaning the plan did not qualify under ERISA’s safe harbor provision. “These facts establish the Agency was not involved in the simple purchase of insurance on behalf of its employees. Instead, the Agency had an ongoing administrative scheme that promised specific benefits to employees and required ongoing monitoring by Steigleman. The extent of the Agency’s involvement in its employees’ benefits also raised the possibility of abuse, providing an additional reason to conclude ERISA applies.” Nor would any employee reasonably review the coverage as not being endorsed by Ms. Steigleman’s agency. Thus, the court concluded that the agency established a benefits package for its employees and by doing so created an ERISA-governed employee welfare benefit plan, regardless of whether it intended to or not.

Tenth Circuit

Faris v. S. Ute Indian Tribe, No. 23-cv-00245-NYW-STV, 2023 WL 7386870 (D. Colo. Nov. 8, 2023) (Judge Nina Y. Wang). Plaintiff Michelle Faris brought this ERISA Section 510 and breach of fiduciary duty action against her former employer, the Red Willow Production Company, believing the company “fabricated a for-cause termination”  to avoid paying her increased distribution payments under an employee benefit plan. That plan, the Long Term Incentive Plan, was the central focus of this decision. Specifically, the decision discussed whether the plan is a bonus plan or a traditional retirement plan, and if it is a bonus program, whether it systematically defers payment to the termination of covered employment and is therefore subject to ERISA. This dispute was central to defendants’ motion to dismiss pursuant to Rule 12(b)(1) for lack of subject matter jurisdiction. In its decision, the court concluded that the plan is excluded from ERISA coverage and ERISA therefore does not govern Ms. Faris’ claims. It agreed with defendants that the plan is properly categorized as a bonus plan as its purpose is to “reward and retain eligible employees of the Growth Fund and its business enterprises,” rather than provide retirement income. Moreover, it found that the plan does not systematically defer payments to the termination of employment, and “any post-termination distributions are the result of ‘happenstance,’ not the systematic deferral of payment to the termination of employment or beyond.” Accordingly, the court granted the motion to dismiss for lack of subject matter jurisdiction.

Pleading Issues & Procedure

First Circuit

Cutway v. The Hartford Life & Accident Co., No. 2:22-cv-00113-LEW, 2023 WL 7386371 (D. Me. Nov. 8, 2023) (Magistrate Judge John C. Nivison). Plaintiff Kevin Cutway commenced this ERISA action seeking a court order reinstating disability benefits that defendant Hartford Life & Accident Company suspended to offset an overpayment of benefits. The parties agree that the plan provides for an offset of disability benefits paid by the Social Security Administration. However, Mr. Cutway disagrees with Hartford that it was entitled to a setoff of all the amounts paid by the Social Security Administration and to suspend his benefits altogether. The parties filed motions for judgment on the record and oppositions to each other’s motions. As part of his opposition, Mr. Cutway “filed an affirmation in which he recounted communications he had with Defendant regarding the amount he was receiving in social security benefits.” He also filed a reply memorandum. Hartford moved to strike both Mr. Cutway’s affirmation and reply memorandum. It argued that Mr. Cutway impermissibly modified the administrative record with his affirmation and that his reply was in direct contravention of the court’s scheduling order. The court agreed with Hartford. It struck the reply memorandum, as it was not explicitly authorized by the scheduling order and because Mr. Cutway did not seek leave of the court to file it. As for the affirmation, the court stressed that it would not allow the administrative record to be altered at this time. “[I]f plaintiff were permitted to supplement the record with the affirmation, presumably Defendant would also seek to supplement the record with additional information regarding communications between the parties. Such a process would be inconsistent with the general rule that the Court’s review is limited to the record before the Plan administrator. The court discerns no reason to deviate from the general rule in this case. Accordingly, even if Plaintiff had filed an appropriate motion, he has not demonstrated sufficient grounds to supplement the record.” Based on the foregoing, the court granted Hartford’s motion to strike, and kept the administrative record unaltered from the version the parties relied upon in their motions for judgment.

Provider Claims

Ninth Circuit

Saloojas, Inc. v. United Healthcare Ins. Co., No. C 22-03536 WHA, 2023 WL 7393016 (N.D. Cal. Nov. 8, 2023) (Judge William Alsup). A healthcare provider that offered COVID-19 testing services throughout the pandemic, Saloojas, Inc., brought this putative class action against United Healthcare Insurance Company for failure to pay for its services. Saloojas has commenced several of these actions with different insurers subbed in as the defendants. In each, it alleges that the insurance provider, here United, violated the CARES Act, the Families First Coronavirus Response Act (“FFCRA”), ERISA, and RICO, as well as state law promissory estoppel and fraud. Other courts in the district have dismissed Saloojas’s actions. Here, this court joined in, granting United’s motion to dismiss for failure to state a claim. Like the other decisions, the court here concluded that the CARES Act and FFCRA do not create private rights of action for healthcare providers. These two claims were dismissed with prejudice. Saloojas’ ERISA claim was dismissed, without prejudice, as the complaint fails to allege the provider received assignments of benefits from patients insured under ERISA plans. The court stated that Saloojas may seek leave to amend its ERISA claim to allege specific language of assignment. The RICO and state law fraud claims were dismissed because the court found that the provider failed to satisfy Rule 9(b)’s heightened pleading standard. Like the ERISA claim, these causes of action were dismissed without prejudice. Finally, the court concluded that the promissory estoppel claim failed because Saloojas did not identify any clear and unambiguous promise by United to reimburse it for the COVID-19 testing.

Standard of Review

Eleventh Circuit

Givens v. Nextran Corp., No. 3:22-cv-733-TJC-MCR, 2023 WL 7284769 (M.D. Fla. Oct. 27, 2023) (Judge Timothy J. Corrigan). In order to rule on a benefit determination under an ERISA-governed healthcare plan, the court ordered the parties to submit supplemental briefing on whether the de novo or arbitrary and capricious standard of review applies this action. In this order it ruled that the case will proceed under a de novo standard of review. In this short decision, the court stressed that deviation from the default de novo review standard requires “a clear and explicit grant of discretion.” Here, the court held that the Nextran health plan does not expressly grant discretionary authority. Rather, the plan uses such language as “decided,” “interpretation,” “good faith,” and “best interest of the member.” These phrases, the court stated, could be viewed as indirectly implying some discretionary decision-making, but certainly do not constitute an explicit grant of discretionary authority. And although the plan allows the fiduciaries to make determinations of the claimant’s eligibility, the court ruled that the plan language does not trigger deferential review. Finally, the court declined to incorporate the language of a second ERISA plan offered by the employer to alter the standard of review for the health plan at issue. In essence, the court found the other plan’s connection to the operative group health plan to be tenuous and concluded that its language, including its express grant of discretionary authority, not applicable to this case. Accordingly, when it comes time, the court will rule on the adverse benefit determination at the center of this action under the de novo standard of review. 

Venue

Tenth Circuit

K.A. v. UnitedHealthcare Ins. Co., No. 2:23-cv-00315-RJS-JCB, 2023 WL 7282544 (D. Utah Nov. 3, 2023) (Judge Robert J. Shelby). Plaintiff K.A. sued UnitedHealthcare Insurance Company and United Behavioral Health in this one-count ERISA action after the insurance company denied a benefit claim for the residential mental health treatment of K.A.’s minor daughter, L.A. United moved to transfer venue. Its motion was granted here. Father and daughter are residents of Illinois. L.A.’s treatment facility was located in Missouri. United is headquartered in the business-friendly state of Connecticut. And the plan sponsor is located in Arizona. As none of the parties, operative facts, or relevant events had any connection to the state of Utah, the court afforded little weight to plaintiff’s choice of forum. The only connection to the District of Utah was the office of plaintiff’s attorney, located in Salt Lake City. This tie to the state, on its own, was seen by the court as too tenuous a connection to justify keeping the lawsuit in the district. Instead, given the lack of a meaningful connection to the District of Utah, the court agreed with United that the Northern District of Illinois, where K.A. and L.A. reside and where the alleged breach occurred, was a more appropriate and convenient venue for this action. For these reasons, the court found that it was in the interest of justice to move the case, and United’s motion to transfer the lawsuit to the Northern District of Illinois was thus granted.

This week sets the all-time record for a slow week in the courts, with only three relevant ERISA decisions reported. Although Your ERISA Watch normally focusses on case law, given the dearth of material we are dispensing with the Case of the Week and instead discussing a Regulation of the Week. After all, it was big news on October 31 when the Department of Labor dropped its latest proposal regarding the regulation of fiduciary investment advisors, a topic with a long and tortuous history.

Because life is short (so many interesting ERISA issues, so little time), I won’t attempt a complete analysis of that history or the latest proposed regulation and exemptions. Instead, I will offer a few thoughts about the proposal.

But first, the history in a nutshell. ERISA includes within its broad and functional definition of fiduciary a person who “renders investment advice for a fee or other compensation, direct or indirect, with respect to any moneys or other property of such plan, or has any authority or responsibility to do so.” 29 U.S.C. § 1002(21)(A)(ii). Sounds straightforward enough.

However, in 1975, shortly after ERISA was enacted, the DOL promulgated an investment advisor regulation that appeared to convert a two-part statutory test for determining whether a person rendering investment advice is a plan fiduciary into a five-part test, with at least two parts seemingly pulled out of thin air. Under this regulation, in addition to the statutory requirements that the person in question must (1) render investment advice (including as to the value of plan property) (2) for a direct or indirect fee or other compensation, the regulations added the requirements that (3) the advice be “pursuant to mutual agreement, arrangement, or understanding” with the plan or plan fiduciary, (4) the advice “will serve as the primary basis for investment decisions with respect to plan assets,” and (5) the person in question “will render individualized investment advice to the plan based on the particular needs of the plan regarding such matters as, among other things, investment policies or strategy, overall portfolio composition, or diversification of plan investments.” 29 C.F.R. § 2510.3-21(a)(1). The IRS promulgated a nearly identical regulation. The DOL also issued an advisory opinion in 2005 (A.O. 2005-23A or the “Deseret Letter”), which stated that advice about distribution options from a plan, including about where to invest such distributions, was not covered fiduciary advice.

Whew. Needless to say, this regulatory definition significantly narrowed the universe of plan advisors that one would expect to be considered fiduciaries under the statutory definition. For this reason, particularly after the rise of 401(k) and other defined contribution plans, the DOL began to consider reining in this regulation in order to hew more closely to what seems to have been the congressional intent to cover all paid plan investment advisors. However, the DOL found that once it had opened up a sizable loophole, narrowing it again would be a difficult task.  

Although the DOL began the formal process of reconsidering the regulation in 2010, it wasn’t until 2016 that it issued two notices of proposed rulemaking and held hearings, and then issued a final rule and two new prohibited transaction exemptions (as well as amendments to a number of others). Among other things, the changes were designed to cover many kinds of one-time advice, retract the Deseret Letter by covering recommendations to rollover ERISA plan and IRA assets, make the regulation applicable to IRAs, and require that advisors act in the best interest of the plans and IRAs.

The DOL’s regulatory actions were immediately challenged in multiple lawsuits filed in federal courts across the country. District courts in the District of Columbia, Texas, and Kansas, as well as the Tenth Circuit Court of Appeals, upheld the final rule as well within the authority of the DOL (and indeed more consistent with the statutory language). But none of that mattered because the Fifth Circuit overturned the Texas judge’s ruling and vacated the 2016 rule in its entirety. The Fifth Circuit expressed concern that the DOL had untethered fiduciary status from notions of trust and confidence and that the DOL had exceeded its authority through rulemaking that covered not only Title I ERISA plans but also IRAs governed by Title II.

Well, that was a rather big nutshell, and you’ll have to trust me that I didn’t cover everything. But I am guessing that the pressing questions for our readers (at least those who have read so far) are how the current proposal differs from the 2016 rulemaking, what changes are likely to be made to the proposal during the rulemaking process, and what the chances are of a new final regulation surviving a challenge. As with most things in this area of the law, the answer is complicated.

First, some of the changes from the 2016 regulation that jumped out at me are that the proposal (1) mostly swaps out the language referring to plans and IRAs for the term “retirement investor,” (2) changes the focus of the “regular basis” prong of the 1975 test from the retirement investor to the advisor (that is, the advisor has to make investment recommendations on a regular basis), (3) states that the recommendation must be made under circumstances that indicate it is individualized, reliable, and in the investor’s best interest, and (4) states that written disclaimers of fiduciary status will not control over “oral communications, marketing materials, applicable State or Federal Law, or other interactions with the retirement investor.”

It is difficult to know how much of this proposal will change before the DOL issues a final rule because the DOL must of course be responsive to the comments it receives. But we are talking about at least the third rodeo for the DOL on these issues, so my best guess is that this was very well considered, and changes are likely to be around the edges. I did wonder if the DOL might consider a severability provision. I actually think that is unlikely, but it could conceivably help some of the regulation survive.

This brings us to the last question. Whether the final rule will survive, in whole or in part, the legal challenges that are sure to follow present the toughest test of all because they depend in part on what the final rule looks like, and on who the reviewing judges are. But the DOL certainly made an effort to address the Fifth Circuit’s trust law concerns and also did an excellent job explaining the importance of the issues from an economic and societal perspective.

If you want to dig into the new regulations for yourself, feel free to visit the links below:

Proposed Retirement Security Rule

Proposed Amendment to PTE 2020–02

Proposed Amendment to PTE 84–24

Proposed Amendment to PTEs 75–1, 77–4, 80–83, 83–1, and 86–128

Below is a summary of this past week’s notable ERISA decisions by subject matter and jurisdiction.

ERISA Preemption

Seventh Circuit

Stanford Health Care v. Health Care Serv. Corp., No. 23-cv-4744, 2023 WL 7182990 (N.D. Ill. Nov. 1, 2023) (Judge Joan B. Gottschall). Plaintiff Stanford Health Care, a healthcare provider in California, sued Health Care Service Corporation d/b/a Blue Cross and Blue Shield of Illinois and Blue Cross and Blue Shield of Texas, in Illinois state court alleging claims of breach of implied contract and, pled in the alternative, quantum meruit, for the insurer’s failure to reimburse it at the costs agreed upon in a contract it entered into with Anthem Blue Cross, the parent association of which Health Care Service Corporation is a member. Stanford Health maintains that Health Care Service Corp. has not paid either the discounted agreed-upon rates set out in the contract nor the usual and customary cost of the services at issue. Defendant removed the action to federal court, arguing that ERISA preempts the claims asserted. Stanford Health disagreed, and moved to remand the action back to state court. The court granted the motion to remand in this decision. It agreed with the provider that this action is not a lawsuit seeking to recover benefits under an ERISA plan, to enforce plan rights, or to determine rights to any future benefits under the terms of an ERISA plan. Instead, it ruled that Stanford Health brought non-preempted “rate claims” as a medical provider to enforce terms of a contract unrelated to any ERISA plan. The court expressed that Stanford Health’s claims are about the amount of payment and not the right to payment, meaning “there is no need to interpret an ERISA plan because the rate to be paid is external from the ERISA plan.” Accordingly, the court concluded that there were no grounds for removal because ERISA does not completely preempt the two state law causes of action.

Life Insurance & AD&D Benefit Claims

Fifth Circuit

Metropolitan Life Ins. Co. v. Muecke, No. 22-01029, 2023 WL 7131041 (W.D. La. Oct. 30, 2023) (Judge Donald E. Walter). Interpleader plaintiff Metropolitan Life Insurance Company commenced this action after two individuals submitted claims to recover life insurance benefits from an ERISA-governed life insurance policy belonging to decedent Joe Nickle. Those two individuals, Mr. Nickle’s son, Cameron Nickle, and Joe Nickle’s girlfriend, Deanna Muecke, each moved for summary judgment and to be awarded the $20,000 in benefits plus interest. In this decision the court granted judgment in favor of Ms. Muecke because she was the named beneficiary of the policy. The court rejected the younger Mr. Nickle’s arguments that Ms. Muecke was fraudulently listed as the beneficiary and that the elder Mr. Nickle was under undue influence, misled, and deceived by Ms. Muecke when naming her as the beneficiary. The court found these allegations advanced by Cameron Nickle to be speculative, not alleged with sufficient particularity, and presented without competent supporting evidence. Accordingly, the court honored the elder Mr. Nickle’s beneficiary designation and paid the benefits to Ms. Muecke according to his wishes.

Withdrawal Liability & Unpaid Contributions

Fifth Circuit

New Orleans Employers Int’l Longshoremen’s Ass’n, AFL-CIO Pension Fund v. United Stevedoring of Am., No. 22-2566, 2023 WL 7220551 (E.D. La. Nov. 2, 2023) (Judge Ivan L.R. Lemelle). More than a year ago, plaintiffs New Orleans Employers International Longshoremen’s Association, AFL-CIO Pension Fund and its administrator commenced this ERISA civil enforcement action against two defendants, United Stevedoring of America, Inc. and American Guard Services, Inc., which are companies they believe to be a controlled group or a single employer for the purposes of withdrawal liability. In March of 2021, United Stevedoring’s collective bargaining agreement was terminated, and the employer completely withdrew from the pension fund. The next month, plaintiffs sent notice to the employer of its withdrawal assessment and demanded payment. United Stevedoring subsequently requested additional information from the fund to which plaintiffs responded on April 12, 2022. That response started a sixty-day clock for the employer to initiate arbitration should it wish to contest the fund’s assessed amount of withdrawal liability. By June 11, 2022, the date when the window to initiate arbitration ended, United Stevedoring had not filed for arbitration with the American Arbitration Association. The company would not do so for over a year, after this lawsuit was filed, while the discovery process was underway. Instead, the only action related to initiating arbitration proceedings that the employer took within the sixty-day window was to send an email to plaintiffs on June 2, 2022, requesting a list of recommendations for arbitrators to facilitate the arbitration process. Defendants maintain that this action bolsters their claim that they tried to arbitrate their dispute over the assessed amount of withdrawal liability but were frustrated and divested of their right to initiate arbitration. Thus, defendants argued that the clock to do so should be reset. Operating under this belief, defendants moved to compel arbitration. The court was not persuaded. It held that defendants failed to timely initiate arbitration proceedings. “The statutory text…makes clear both the arbitration deadlines and the consequences for neglecting them. Beyond-deadline arbitration demands are improper.” Defendants’ email to plaintiffs was not interpreted by the court as a written demand for arbitration. It also rejected their “strained textual reading of their [collective bargaining] agreement.” Pointing out that the agreement incorporates ERISA’s default rules concerning arbitration proceedings for employers who wish to contest withdrawal assessments, the court ruled that defendants were negligent in timely initiating arbitration, and that the time to do so has passed. Thus, it concluded arbitration is no longer available. Defendants’ motion to compel arbitration was accordingly denied.