Justia U.S. 2nd Circuit Court of Appeals Opinion Summaries

Home health care plaintiffs sought to prevent the Commissioner of the New York State Department of Health, from enforcing the Wage Parity Law, which sets the minimum amount of total compensation that employers must pay home care aides in order to receive Medicaid reimbursements for reimbursable care provided in New York City and Westchester, Suffolk, and Nassau Counties, N.Y. Pub. Health Law 3614‐c. Plaintiffs claim the Law was either preempted by the National Labor Relations 8 Act, 29 U.S.C. 151, or the Employee Retirement Income Security Act, 29 U.S.C. 1001, or was unconstitutional under the Due Process and Equal Protection Clauses. The Second Circuit affirmed the district court conclusion that the state law, except for one severable provision subdivision that singles out Taft‐Hartley plans for special treatment, is neither preempted nor unconstitutional. View "Concerned Home Care Providers, Inc. v. Cuomo" on Justia Law

The Chapter 7 bankruptcy trustee appealed the district court's holding that the bankruptcy court did not have jurisdiction to order that he and his retained professionals be compensated for their services using the assets of a 401(k) plan pursuant to the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1001 et seq. The court concluded that, in this case, no "arising under" jurisdiction exists and no "related to" jurisdiction exists. Accordingly, the court concluded that bankruptcy courts do not have jurisdiction to award compensation to the trustee in these circumstances and affirmed the judgment of the district court. View "Kirschenbaum v. U.S. Dept. of Labor" on Justia Law

Plaintiffs, individual CIGNA Plan participants, filed suit on behalf of themselves and others similarly situated, alleging that CIGNA defendants made misleading communications in regards to the terms of the Plan. Subsequently, on remand, the court concluded that the district court acted within the scope of its discretion in denying CIGNA's motion to decertify the plaintiff class; the district court did not abuse its discretion in determining that the elements of reformation have been satisfied and that the Plan should be reformed to adhere to representations made by the plan administrator; and, in this case, the district court did not abuse its discretion in limiting relief to A+B benefits rather than ordering a return to the terms of CIGNA's original retirement plan. View "Amara v. CIGNA Corp." on Justia Law

This case arose from injuries suffered by several students during scholastic athletic activities. The students were insured by Central States, an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., employee welfare benefit plan that provides health insurance to participating Teamsters and their dependents. The students were also directly insured by separate accident policies written by Gerber. Central States subsequently filed suit against Gerber, alleging various claims for declaratory judgment and injunctive relief pursuant to federal common law and ERISA section 502(a)(3). The court held that although Central States might well be left without an appropriate remedy as a result of this decision, and that in the future its beneficiaries may be put in the unfortunate position of having to sue their insurance companies to receive benefits to which they are indisputably entitled, the claims raised by Central States are legal, not equitable, and therefore may not be brought under section 502(a)(3). Accordingly, the court affirmed the district court's grant of Gerber's motion to dismiss under Rule 12(b)(6). View "Cent. States, Se. & Sw Areas Health & Welfare Fund v. Gerber Life Ins. Co." on Justia Law

The UMM Fund filed suit asserting three claims against the 210 Fund. The district court construed all three claims as pleading causes of action under section 502 of ERISA, 29 U.S.C. 1132(a)(3)(B), which provides a federal civil cause of action to an ERISA plan fiduciary to obtain equitable relief for harms resulting from violations of the terms of an ERISA plan and ERISA. The court concluded that the Section 515 claim was properly dismissed because the 210 Fund is not an employer and the 210 Fund's payments to the UMM Fund were not made in the interest of an employer; the district court erred in granting summary judgment in favor of the UMM Fund on its first two claims because the terms of each collective bargaining agreement (CBA) were not terms of an ERISA plan; and, although the UMM Fund has failed to state a claim under ERISA, the first two claims in the Amended Complaint can be construed as state law breach-of-contract claims. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings.View "Silverman v. Teamsters Local 210 Affiliated Health & Ins. Fund." on Justia Law

Plaintiffs initially filed suit in state court seeking to enjoin defendant insurers under New York law from obtaining reimbursement of medical benefits from plaintiffs' tort settlements. Defendants removed to federal court where the district court granted defendants' motion to dismiss under Rule 12(b)(6). The court held that plaintiffs' claims did not satisfy the Supreme Court's test for being subject to complete Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., preemption, which would have conferred federal subject-matter jurisdiction; such jurisdiction exists, however, under the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d); therefore, the court reached the merits of the express preemption defense and concluded that N.Y. Gen. Oblig. Law 5-335 is saved from express preemption under ERISA section 514, as a law that "regulates insurance;" and therefore, the court vacated and remanded for further proceedings.View "Wurtz v. The Rawlings Co." on Justia Law

Plaintiff filed suit against her employer, Reliastar, under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., after she was denied long term disability benefits. The district court found that Reliastar's benefits determination was arbitrary and capricious, and remanded to the company to calculate the amount of benefits owed. Reliastar appealed. The court dismissed the appeal for lack of appellate jurisdiction, holding that the remand order is not an immediately appealable final decision under either the traditional principles of finality or the court's precedents governing remands to administrative agencies. View "Mead v. Reliastar Life Ins. Co." on Justia Law

Plaintiffs, a class of individuals who participated in the Morgan Stanley 401(k) Plan and the Morgan Stanley Employee Stock Ownership Plan, filed suit alleging violations of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. In January 2007 and 2008, Morgan Stanley elected to make its employer contributions to the Plans in the form of Company Stock instead of cash. After the stock price plunged in conjunction with the broader economic downturn, plaintiffs sought to recover for losses the Plans suffered as a result of the drop in stock price. The Moench "presumption of prudence" is a pleading standard that presumes plan fiduciaries act in "compliance with ERISA when [a plan] fiduciary invests assets in the employer's stock." The district court found that the Moench presumption of prudence applied to defendants' conduct and that plaintiffs failed to rebut this presumption. The court affirmed the district court's motion to dismiss on the district court's alternative ground because the challenged conduct, even if it negatively impacted the Plans, did not occur in the performance of a fiduciary function and therefore could not trigger fiduciary liability under ERISA. Absent fiduciary liability, plaintiffs' secondary claims also failed. View "Coulter, et al. v. Morgan Stanley & Co. Inc., et al." on Justia Law

Plaintiffs filed suit against the Plan under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1054(g). At issue was whether the anti-cutback rule in section 204(g) precluded plan amendments that reduced retirement-type subsidiaries for plan participants who have ceased employment without satisfying the preamendment conditions for the subsidy, but who could later satisfy the preamendment conditions without returning to work. The court held that the rule protected such benefits. Plaintiffs have satisfied the preamendment conditions and their benefits were protected by the anti-cutback rule. Accordingly, the court affirmed the judgment of the district court. View "Alcantara v. Bakery and Confectionery Union" on Justia Law

In 2004, plaintiff appealed the denial of his long term disability (LTD) benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Liberty moved for summary judgment. In a 2009 Report and Recommendation (R&R), the magistrate judge recommended denying Liberty's motion and granting summary judgment sua sponte to plaintiff. In 2012, the district court adopted the R&R and entered summary judgment for plaintiff, but denied his request for attorneys' fees. The court concluded that the district court did not err in granting summary judgment on plaintiff's claim for LTD benefits because Liberty's denial of LTD benefits was arbitrary and capricious where Liberty ignored substantial evidence from plaintiff's treating physician that he was incapable of performing his current occupation, while failing to offer any reliable evidence to the contrary; the court retained discretion to consider the Chambless v. Masters, Mates & Pilots Pension Plan factors, in determining whether to grant an eligible plaintiff's request for attorneys' fees, but must do so in a manner consistent with the court's case law, and could not selectively consider some factors while ignoring others; the district court misapplied the Chambliss framework, and therefore erred, in denying fees to a prevailing plaintiff primarily on the conclusion that Liberty had not acted in bad faith; and the record revealed no particular justification for denying plaintiff's attorneys' fees, and awarding fees in the circumstances presented here furthered the policy interest in vindicating the rights secured by ERISA. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Donachie v. Liberty Mutual Ins. Co., et al." on Justia Law