Justia U.S. 4th Circuit Court of Appeals Opinion Summaries

Articles Posted in ERISA

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Plaintiff filed suit against his employer, Sears, alleging misrepresentation, constructive fraud, and infliction of emotional distress. Specifically, plaintiff alleged that Sears improperly administered life insurance benefits. The district court dismissed the complaint. Sonoco Prods. Co. v. Physicians Health Plan, Inc. held that section 502(a) of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a), preempts a state law claim when: the plaintiff has standing, the claim must fail under the scope of an ERISA provision that can enforce via section 502(a), and the claim must not be capable of resolution without an interpretation of the contract governed by federal law. Because plaintiff's claims meets all three prongs of the Sonoco test, the court concluded that ERISA completely preempts his claims. Accordingly, the court affirmed the judgment. View "Prince v. Sears Holdings Corp." on Justia Law
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After PSI stopped contributing to the Fund, a multiemployer pension benefit plan governed by the Employment Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., the Fund informed PSI that it owed "withdrawal liability" pursuant to section 1381. The Fund filed suit against PSI after PSI failed to pay the sum owed. The court affirmed the judgment, finding that the district court had personal and subject matter jurisdiction, venue was proper in Virginia, and PSI bound itself to make contributions to the Fund. View "Trustees of the Plumbers v. Plumbing Svc." on Justia Law
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Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., seeking disgorgement from an employer who wrongly transferred assets from a pension plan that enjoyed a separate account feature to a pension plan that lacked one. The district court dismissed the complaint, holding that plaintiffs lacked statutory and Article III standing. The court held, however, that a defined contribution plan’s separate account feature constitutes an “accrued benefit” that “may not be decreased by amendment of the plan” under section 204(g)(1). In this case, the transfers at issue resulted in a loss of the separate account feature and thus violated section 204(g)(1). Therefore, plaintiffs have statutory standing. Further, plaintiffs have Article III standing where plaintiffs incurred an injury in fact, and satisfied the causation and redressability requirements. Finally, the court joined the majority of its sister circuits and held that the transferor court’s choice-of-law rules apply when a case has been transferred pursuant to 28 U.S.C. § 1404(a). Here, the court concluded that the statute of limitations cannot serve as a basis for affirming the district court's grant of summary judgment to the Bank. Accordingly, the court reversed and remanded for further proceedings. View "Pender v. Bank of America Corp." on Justia Law
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Plaintiff filed suit against Wells Fargo under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132, alleging that the company improperly terminated her short-term disability benefits while she was undergoing a series of treatments for thyroid disease. The district court found insufficient evidence of disability under the Plan to conclude that Wells Fargo abused its discretion in denying plaintiff's claim. The court held that Wells Fargo failed to meet its statutory and Plan obligations to plaintiff as a beneficiary. By failing to contact plaintiff's psychologist when it was on notice that plaintiff was seeking treatment for mental health conditions and when it had his contact information, as well as properly signed release forms from plaintiff, the plan administrator chose to remain willfully blind to readily available information that may well have confirmed plaintiff's theory of disability. Accordingly, the court reversed and remanded with directions to return the case to Wells Fargo for a full and fair review of plaintiff's claims. View "Harrison v. Wells Fargo Bank, N.A." on Justia Law
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Plaintiff filed suit on behalf of himself and other participants in RJR's 401(k) retirement savings plan (collectively, "the participants"), alleging that RJR breached its fiduciary duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., when it liquidated two funds. The court affirmed the district court's holding that RJR breached its duty of procedural prudence and therefore bore the burden of proof as to causation. The court concluded, however, that the district court failed to apply the correct "would have" instead of "could have" legal standard in assessing RJR's liability. Accordingly, the court reversed and remanded for the district court to determine whether, under the correct legal standard, RJR's imprudence caused that loss. View "Tatum v. RJR Pension Investment Committee" on Justia Law
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Plaintiff brought this action under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., against AT&T after her claim to recoup her lost benefits was denied. The district court found that AT&T unreasonably denied plaintiff's claim and failed to adequately notify her of a material change to its pension plan that allowed her to collect full benefits earlier than she had originally understood. The court held that the district court properly considered limited evidence outside of the administrative record but known to AT&T when it rendered plaintiff's benefits determination; correctly determined that AT&T breached its statutory and fiduciary duties to plaintiff; and did not err in awarding plaintiff her lost benefits. Accordingly, the court affirmed the judgment. View "Helton v. AT&T Inc." on Justia Law

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Plaintiff brought this declaratory judgment action, asserting that the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., preempted a state court order requiring him to turn over benefits received under ERISA retirement and life insurance plans owned by his deceased ex-wife. At issue was whether ERISA prohibited a state court from ordering plaintiff, who had previously waived his right to those benefits, to relinquish them to the administrators of the ex-wife's estate. The court held that ERISA did not preempt post-distribution suits against ERISA beneficiaries because the court detected no conflict with either ERISA's objectives or relevant Supreme Court precedent. Accordingly, the court affirmed the judgment. View "Andochick v. Byrd" on Justia Law

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Plaintiffs brought this civil enforcement action under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., alleging that defendants, the Bank, and individual members of the Bank's Corporate Benefits Committee, engaged in prohibited transactions and breached their fiduciary duties by selecting and maintaining Bank-affiliated mutual funds in the investment menu for the Bank's 401(k) Plan and the Bank's separate but related Pension Plan (collectively, the Plans). The court affirmed the district court's dismissal of the Pension Plan claims in the Second Amended Complaint on the basis that plaintiffs lacked Article III standing. The district court correctly determined that plaintiffs' remaining claims were time-barred under the limitations period in 29 U.S.C. 1113(1)(A). Finally, the district court's dismissal of the Third Amended Complaint with prejudice did not constitute an abuse of discretion where plaintiffs failed to file a motion to amend and had already amended their original complaint three times. Accordingly, the court affirmed the judgment of the district court. View "David v. Alphin" on Justia Law

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This dispute related to Employee Retirement Security Act (ERISA), 29 U.S.C. 1001 et seq., contributions made pursuant to a collective bargaining agreement. The district court ordered return of certain allegedly mistaken employer contributions even though the plan administrator determined that the contributions were not made by mistake. Because the court found that the administrator's decision was not an abuse of discretion, the court reversed and remanded for further proceedings. View "U.S. Foodservice, Inc. v. Truck Drivers & Helpers Union" on Justia Law

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Plaintiffs David McCorkle and William Pender appealed a district court order dismissing two of their class action claims against Bank of America Corporation for alleged violations of certain provisions of the Employment Retirement Income Security Act of 1974 (ERISA). Their claims centered on the Bank's use of a normal retirement age (NRA) that allegedly violated ERISA in calculating lump sum distributions and further ran afoul of ERISA's prohibition of "backloading" the calculation of benefit accrual. Upon review, the Fourth Circuit agreed with the district court's conclusion that Plaintiffs failed to state a claim upon which relief could be granted, and it affirmed the district court's judgment to dismiss those claims. View "Pender v. Bank of America Corp." on Justia Law