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

The Fourth Circuit affirmed the district court's judgment requiring Just Born, a candy manufacturer, to pay delinquent contributions into the Bakery and Confectionary Union and Industry International Pension Fund, as well as interest, statutory damages, and attorneys' fees. Under a plain-language application of the Provision to the facts of this case, the court held that Just Born was liable to the Pension Fund for continued contributions for all employees hired after the declaration of an impasse, pending the execution of a new collective bargaining agreement (CBA) in compliance with section 1085 of the Employee Retirement Income Security Act (ERISA), the invocation of the withdrawal provisions, or some other statutorily required act. Accordingly, the Pension Fund was entitled to judgment on the pleadings so long as Just Born did not present a cognizable affirmative defense. The court agreed with the district court's reasoning that the Rule 9(b) standard applied to Just Born's affirmative defenses and that Just Born's allegations did not satisfy this standard. Therefore, the district court did not err in concluding that Just Born did not plead its affirmative defenses with sufficient particularity to withstand the Pension Fund's motion for judgment on the pleadings. View "Bakery and Confectionary Union v. Just Born II, Inc." on Justia Law

The Fourth Circuit affirmed the district court's denial of class certification and grant of summary judgment for CSC in an action filed by former executives pursuant to section 1132(a) of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs alleged denial of benefits under their deferred executive compensation plan after a plan amendment changed the applicable crediting rate, and sought class certification on behalf of all retired plan participants affected by the amendment. The court declined to decide which standards of review applied because the competing standards of review presented a distinction without a difference. Whether the court proceeded under a reasonableness inquiry, an abuse-of-discretion standard, or even de novo review, the 2012 Amendment and CSC's denial of benefits were valid. View "Plotnick v. Computer Sciences Corp." on Justia Law

This case arose out of an underlying action to enforce the health benefits provisions of two court-approved settlement agreements. The Fourth Circuit affirmed the district court's denial of plaintiffs' motion for a preliminary injunction. The court held that a motion for preliminary injunction filed before the act to be enjoined has occurred, and subsequently intended to restore the status quo once it has been disturbed, was not moot. The court also held that the district court had jurisdiction over plaintiffs' claim pursuant to Section 502(a)(1)(B) of the Employee Retirement Income Security Act (ERISA). On the merits, the court held that the district court did not abuse its discretion in finding that plaintiffs failed to demonstrate a likelihood of success on the merits; that they were likely to suffer irreparable harm without a preliminary injunction; and that the balance of the equities and the public interest favor an injunction. View "Di Biase v. SPX Corp." on Justia Law

Plaintiffs filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., to recover alleged overpayments of retirement benefits to certain employees of DAK who were participants in the Plan. The Fourth Circuit held that the written language of the Plan clearly and unambiguously provided the lump sum elected by the employees was the actuarial equivalent of the Accrued Benefit payable at the employee's Normal Retirement Date. Therefore, the court affirmed the district court's award of summary judgment to plaintiffs on their equitable restitution claim. The court also held that the doctrine of equitable estoppel could not be used to require the payment of benefits that conflict with the express, written terms of the Plan; the court assumed, without deciding, that the particular facts of this case could establish a finding that plaintiffs breached their fiduciary duty and turned instead to consider whether any of the employees established a triable issue of fact as to "actual harm" in connection with their claims for a surcharge remedy; and Rodney B. Smith was the only employee with a viable surcharge claim for purposes of summary judgment. Accordingly, the court vacated the judgment against Smith and remanded for further proceedings. View "Retirement Committee of DAK Americas v. Brewer" on Justia Law

Plaintiff filed suit under section 502(a)(1)(B) of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)(B), after the plan administrator determined that plaintiff's disability-onset date rendered him ineligible for benefits. The Fourth Circuit affirmed the district court's conclusion that plaintiff was entitled to benefits and order requiring the Plan to provide the benefits. The court explained that the Board failed to follow a reasoned process or explain the basis of its determination -- neither addressing nor even acknowledging new and uncontradicted evidence supporting plaintiff's application, including that of the Plan's own expert. View "Solomon v. Bert Bell/Pete Rozelle NFL Player Retirement Plan" on Justia Law

The court affirmed the district court's finding that, under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., a plan fiduciary's breach did not cause substantial losses to the retirement plan because a prudent fiduciary would have made the same divestment decision at the same time and in the same manner. The district court explained that a prudent fiduciary would have balanced the increased risk of loss that the Nabisco Funds brought to the Plan against the Funds' likely average returns. The court concluded that the district court's findings and analysis entirely accord with the efficient market hypothesis and Fifth Third Bancorp v. Dudenhoeffer. In this case, a prudent fiduciary would have concluded the Nabisco Funds' expected returns did not justify the increased risk of loss to the plan, especially because ERISA requires that a fiduciary diversify plan assets to minimize risk of loss. View "Tatum v. RJR Pension Investment" on Justia Law

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

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

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

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