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

Plaintiffs, former employees of PwC, filed suit under the Employee Retirement Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., alleging that PwC's retirement plan deprived them of so-called "whipsaw payments," which guarantee that plan participants who take distributions in the form of a lump sum when they terminate employment will receive the actuarial equivalent of the value of their accounts at retirement. The PwC plan defines “normal retirement age” as five years of service, so that it coincides with the time at which employees vest in the plan. The court held that the plan’s definition of “normal retirement age” as five years of service violates the statute not because five years of service is not an “age,” but because it bears no plausible relation to “normal retirement,” and is therefore inconsistent with the plain meaning of the statute. Accordingly, the court affirmed the judgment of the district court, but for different reasons than those cited by the district court. The court did not reach the district court's alternative reasons for denying defendants' motion to dismiss. View "Laurent v. PricewaterhouseCoopers LLP" on Justia Law

Plaintiff, a physician, filed suit alleging that his employer Montefiore denied him severance benefits in violation of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. The district court dismissed the complaint for lack of jurisdiction. The court concluded, however, that on the facts alleged in the complaint, the severance policy at issue is a "plan" governed by section 1002(1) of ERISA. The court considered Montefiore's remaining arguments and concluded that they are without merit. Accordingly, the court vacated and remanded. View "Okun v. Montefiore Medical Center" on Justia Law

Plaintiffs, physicians, filed suit against Cigna alleging that Cigna violated the anti-retaliation provisions of ERISA. Plaintiffs moved for a temporary restraining order and preliminary injunction to prohibit Cigna from terminating plaintiffs from its provider network. The district court denied the injunction and plaintiffs appealed. The court held that healthcare providers are not “beneficiaries” of an ERISA welfare plan by virtue of their in‐network status or their entitlement to payment. Patients may assign to their doctors the right to collect payment on their behalf in exchange for medical services, but the doctors in this case do not seek payment; instead, they seek to assert anti‐retaliation protections which were not assigned to them. Accordingly, the court affirmed the judgment. View "Henry L. Rojas, M.D. v. Cigna Health and Life Ins. Co." on Justia Law

The Fund filed suit against Empire under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA), 29 U.S.C. §§ 1381–1453, after Empire effected a "complete withdrawal" from the Fund. Steven Levine was the sole shareholder of Empire. The Fund also filed suit against Enivel to recover on its judgment against Empire, alleging that Enivel is a trade or business under common control with Empire such that it is jointly and severally liable for Empire’s withdrawal liability. At issue was whether a separate business organization can be held responsible for the liabilities of another commonly controlled entity under the Employee Retirement Income Security Act of 1974 (ERISA), as amended by the MPPAA. The court concluded that, although Enivel and Empire are commonly controlled, Enivel’s limited leasing and sales activity was personal in nature - not primarily for profit - and Enivel did not operate continuously and regularly. The owners did not fragment their business operations over several entities. Rather, Enivel’s mission was primarily personal and any profit it derived was incidental. Therefore, the court concluded that Enivel is not a “trade or business” for the purposes of the MPPAA and affirmed the district court's judgment for Enivel. View "UFCW Local One Pension Fund v. Enivel Properties, LLC" on Justia Law

The Hospital filed an interpleader action under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., to resolve competing claims by Barbara Nicholls and Clair Nicholls to certain funds held in the four retirement and pension plans of the late Harold Nicholls. Barbara is Harold's surviving spouse and Claire is Harold's former spouse. The district court granted summary judgment in favor of Claire because the divorce settlement agreement constitutes a qualified domestic relations order (QDRO). The court found that the divorce settlement agreement does not constitute a QDRO because the agreement fails to comply with the requirements of 29 U.S.C. § 1056(d)(3)(C); however, the nunc pro tunc orders constitute valid QDROs that assign funds to Claire from the three retirement and pension plans named in the orders; but because the nunc pro tunc orders do not clearly specify the fourth plan, the orders do not assign funds from that plan to Claire. Accordingly, the court affirmed in part and reversed in part. View "Yale-New Haven Hosp. v. Nicholls" on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., seeking a pension based on permanent disability. On appeal, plaintiff challenged the district court's grant of defendants' motion for summary judgment. The district court granted the motion based on the ground that the Pension Plan gave defendants discretion to determine an applicant's eligibility for pension benefits and that defendants' reliance on SSA determinations, policies, and procedures in this matter was neither arbitrary nor capricious. The court rejected plaintiff's contentions that the real decisionmaker on her benefits applications was the SSA and that the Trustees exercised no discretion but simply rubber-stamped SSA decisions. The court concluded that the district court properly reviewed the Trustees' denial of plaintiff's application under the arbitrary-and-capricious standard. Further, the record also provides no support for plaintiff's contention that the Trustees' denial of her application for a permanent-disability pension was arbitrary and capricious. The court concluded that all of plaintiff's arguments are without merit and the court affirmed the judgment. View "Ocampo v. Building Service 32B-J Pension Fund" on Justia Law

MetLife appealed the district court's judgment in favor of plaintiff on his claim for pension benefits pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court concluded that MetLife's denial of plaintiff's benefits claim was not arbitrary and capricious where MetLife's rationale for denying plaintiff's claim - that it was impossible to determine whether, or to the extent to which, a FINRA award represented back pay - was not, in fact, unreasonable. The court did not reach MetLife's alternative argument. Accordingly, the court reversed the district court's judgment granting plaintiff relief under ERISA. The court affirmed the denial of plaintiff's request for attorney's fees. View "Roganti v. Metro. Life Ins. Co." on Justia Law

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