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

A Vermont statute requires all "health insurers" to file with the State reports containing claims data and other "information relating to health care." Liberty Mutual sought a declaration that the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., preempted the Vermont statute and regulation. The district court granted summary judgment in favor of Vermont. The court held that the reporting requirements of the Vermont statute and regulation have a "connection with" ERISA plans and were therefore preempted as applied. The court's holding was supported by the principle that "reporting" is a core ERISA function shielded from potentially inconsistent and burdensome state regulation. Accordingly, the court reversed and remanded with instructions to enter judgment for Liberty Mutual. View "Liberty Mutual Ins. Co. v. Donegan" on Justia Law

Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., against Xerox, the Plan, and the Plan Administrator. The Supreme Court reversed the court's most recent decision, holding that the court had erred in holding that, having found the Administrator's first interpretation of the retirement plan to be invalid, the district court properly refused to defer to the plan administrator's subsequent interpretation of the plan. On remand, the district court applied deferential review, holding that the Administrator's proposed offset was a reasonable interpretation of the retirement plan. The court held, however, that the proposed offset was an unreasonable interpretation of the retirement plan and that it violated ERISA's notice provisions. Although the court upheld the challenged discovery order, the court vacated the judgment and remanded for further proceedings. View "Frommert v. Conkright" on Justia Law

Plaintiff filed suit against her former employer, Andalex, alleging claims of discrimination, retaliation, and hostile work environment under federal and state law, as well as claims that Andalex failed to notify her of her right to continuing health care coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA), 29 U.S.C. 1166 et seq. The district court granted summary judgment in favor of Andalex and dismissed her claims. The court affirmed the district court's judgment except with respect to plaintiff's retaliation claims. Based on the discrepancies between the EEOC statement and subsequent testimony, a reasonable juror could infer that the explanation given by Andalex was pretextual, and that, coupled with the temporal proximity between the complaint and the termination, the complaint at issue was a but-for cause of defendant's termination. Accordingly, there was sufficient evidence to require denial of the summary judgment motion on the retaliation claims. View "Kwan v. The Andalex Group LLC" on Justia Law

Village Fuel appealed the district court's denial of attorney's fees in an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., action. The court concluded that Village Fuel obtained some degree of success on the merits in defeating GHI's restitution claims and that, under ERISA, a favorable court judgment was not required to satisfy the threshold of awarding attorney's fees. The court vacated and remanded to the district court for further proceedings to determine a reasonable amount of attorney's fees, if any, to be awarded to Village Fuel. View "Scarangella & Sons v. Group Health, Inc." on Justia Law

Plaintiffs, former Lehman employees, filed suit alleging that defendants, members of the Benefits Committee, and the company's Directors, breached their duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. In regards to plaintiffs' claims that the Benefits Committee Defendants breached their duty of prudence in managing the company's employee stock ownership plan (ESOP), the court concluded that plaintiffs have not rebutted the Moench v. Robertson presumption because they failed to allege facts sufficient to show that the Benefits Committee Defendants knew or should have known that Lehman was in a "dire situation" based on information that was publicly available during the class period. In regards to plaintiffs' claims that the Benefits Committee Defendants breached their duty of disclosure, the publicly-known information available to defendants did not give rise to an independent duty to investigate Lehman's SEC filings prior to incorporating their content into a summary plan description issued to plan-participants. The court affirmed the district court's dismissal of plaintiffs' remaining claims. View "In Re: Lehman Bros. ERISA Litig." on Justia Law

Saint Vincent's alleged that Morgan Stanley - the fiduciary manager of the fixed-income portfolio of Saint Vincent Catholic Medical Centers Retirement Plan - violated its fiduciary duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Saint Vincent's alleged that Morgan Stanley disproportionately invested the portfolio's assets in mortgaged-backed securities, including the purportedly riskier subcategory of "nonagency" mortgage-backed securities, despite warning signs that these investments were unsound. Although Saint Vincent's, as the fiduciary administrator of an ERISA-governed plan, was in a position to plead its claims with greater factual detail than was typically accessible to plaintiffs prior to discovery, and although it received two opportunities to amend its complaint, the Amended Complaint failed to plead sufficient, nonconclusory factual allegations to show that Morgan Stanley failed to meet its fiduciary responsibilities under ERISA. Accordingly, the court affirmed the district court's dismissal of the Amended Complaint. View "Pension Benefit Guaranty Corp. v. Morgan Stanley Inv. Mgmt. Inc." on Justia Law

Plaintiff appealed from the district court's grant of Aetna's motion for summary judgment on the issue of whether the insurer improperly denied plaintiff long-term disability benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Because Aetna's reservation of discretion was sufficient to compel use of the arbitrary and capricious standard of review, the court affirmed summary judgment to Aetna on its denial of benefits. The court also held that Aetna's action seeking return of overpaid benefits was properly brought under 29 U.S.C. 1132(a)(3) as an equitable counterclaim. Accordingly, the court reversed the district court's denial of summary judgment on the counterclaim. View "Thurber v. Aetna Life Ins. Co." on Justia Law

Plaintiffs sued the administrators of CAAIG contending that they breached their fiduciary duties to CAAIG under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., by failing to ensure that CAAIG had sufficient assets with which to satisfy the judgment. The district court agreed and entered judgment against the Plan Administrators. The court concluded that LIHS had standing under ERISA 502(a) as a fiduciary of the Plan; the Underfunding Claim and EOC Suffolk Delinquency Claim were timely; the Administrators conceded that the breach of a contractual obligation in the Plan documents constituted a breach of their fiduciary duties under section 404(a)(1) of ERISA; and the Administrators breached their fiduciary duties with respect to the Underfunding Claim and the EOC Suffolk Delinquency Claim. Accordingly, the court affirmed the judgment. View "L.I. Head Start Child Dev. Servs., Inc. v. Economic Opportunity Comm'n of Nassau Cnty., Inc." on Justia Law

Plaintiffs brought a putative class action on behalf of current and former UBS and UBSFS employees, alleging that defendants violated various fiduciary duties imposed on them by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs argued that the district court erred in analyzing their claim for breach of the duty of prudence, as it applied a presumption of prudence to the fiduciaries of both investment plans at issue. The court held that the district court wrongly applied the presumption as to one of the two plans, the Savings and Investment Plan (SIP), as the SIP Plan Document neither required nor strongly encouraged investment in UBS stock or the UBS Stock Fund. The court held, however, that the District Court correctly applied the presumption of prudence as to the second plan, the Plus Plan, which required plan fiduciaries to invest in the UBS Stock Fund. Accordingly, the court affirmed the dismissal order of the district court in part, vacated in part, and remanded the case for further proceedings. Plaintiffs' remaining arguments were addressed in a companion Summary Order. View "Taveras v. UBS AG et al." on Justia Law

Kathy Joy Kirkendall and her co-plaintiffs filed this putative class action suit, pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1002-1461, which included claims for redetermination of benefits and for improper amendment of plan terms. Plaintiffs filed suit without first availing themselves of the procedure described for "benefits claims" in pension plan documents and the district court dismissed based on Kirkendall's failure to exhaust her administrative remedies. The court held that because Kirkendall reasonably interpreted the plan's exhaustion requirement not to apply to a determination of future benefits and did not exhaust her administrative remedies as a result, she was not required to exhaust her administrative remedies. The court also held that Halliburton's actions did not constitute an amendment within the meaning of ERISA section 204(g). View "Kirkendall et al v. Halliburton, Inc. et al" on Justia Law