Justia U.S. 4th Circuit Court of Appeals Opinion SummariesArticles Posted in ERISA
David v. Alphin
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
U.S. Foodservice, Inc. v. Truck Drivers & Helpers Union
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
Pender v. Bank of America Corp.
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
Dickens v. Aetna Life Ins. Co.
Plaintiff filed suit in state court pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., after Aetna terminated his long-term disability benefits under his employer-sponsored plan. Both parties moved for summary judgment, which the district court denied, concluding that relevant evidence had not been adequately addressed, and remanded the case. On appeal, the court held that the collateral order doctrine did not apply in this case and the court dismissed based on lack of subject matter jurisdiction because there was no final decision. View "Dickens v. Aetna Life Ins. Co." on Justia Law
Fortier v. Principal Life Ins. Co.
Plaintiff commenced this action under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., claiming that the administrator of the Principal Life policies had misconstrued the policies in calculating his predisability earnings and that, with a proper calculation, his predisability earnings were far greater. The district court, ruling on cross-motions for summary judgment, entered judgment in favor of Principal Life. The court affirmed. Even though the court recognized that the policy language, defining those expenses that could be subtracted from gross income to arrive at predisability earnings, was somewhat confusing and, to be sure, needlessly verbose, the court concluded that the administrator's interpretation was a reasonable one. View "Fortier v. Principal Life Ins. Co." on Justia Law
Plasterer’s Local Union No. 96 v. Pepper
The former trustees of the Plasterers' Local Union No. 96 Pension Plan appealed from the judgment of the district court in favor of the current trustees of the Plan. The district court's judgment was based on its finding that the former trustees breached their fiduciary duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., regarding the investment Plan assets set forth under 29 U.S.C. 1104(a)(1)(B) and (C). On appeal, the former trustees challenged the district court's determination as to liability, its method of calculating damages, and the award of attorney fees. The court concluded that the district court erred as to each of these issues and therefore vacated the judgment and remanded the case for further proceedings.
Dewhurst, et al. v. Century Aluminum Co., et al.
Retirees filed suit in district court contending that their retiree health benefits were vested and that defendant's intended modification would violate both the Labor Management Relations Act, 29 U.S.C. 185, and the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)(B). Retirees subsequently appealed the denial of their motion for a preliminary injunction seeking continuation of certain healthcare benefits. The court held that the district court issued a thorough and well-reasoned opinion explaining in detail that the retirees failed to establish a likelihood of success on the merits. Accordingly, the court affirmed the district court's denial of the motion for preliminary injunction.
Quesenberry, et al. v. Volvo Trucks North America Retiree Healthcare Benefit Plan, et al.
This case stemmed from the collective bargaining agreement (CBA) between Volvo Group North America, LLC (Volvo) and the union representing workers at Volvo's New River Valley assembly plant (NRV). At issue was whether the CBA permitted Volvo to make unilateral changes to the health benefits of retirees from its NRV assembly plant after the agreement expired. The court held that Volvo was not permitted to make unilateral modifications to the retirees' health benefits after the expiration of the CBA unless it followed the mechanism agreed to by both parties in that agreement. Therefore, the court affirmed the judgment of the district court where Volvo could not employ that mechanism in this case.
Debbie McCravy v. Metropolitan Life Ins. Co.
Plaintiff sued defendant alleging breach of fiduciary duty and sought damages under the "other appropriate equitable relief" provision of the Employee Retirement Income Security Act ("ERISA"), 29 U.S.C. 1132(a)(3), where defendant denied plaintiff's life insurance coverage claims for her deceased daughter on the grounds that her daughter did not qualify for coverage under the plan's "eligible dependent children" provision. At issue was whether section 1132(a)(3) allowed the remedy of surcharge, which would permit recovery of the life insurance proceeds lost by plaintiff because of defendant's breach of fiduciary duty. Also at issue was whether the court should recognize equitable estoppel as part of the common law of ERISA. Further at issue was whether the district court erred in granting plaintiff's motion for summary judgment. The court held that the remedy of surcharge was not available under section 1132(a)(3) and that the district court did not err in limiting plaintiff's damages to the premiums withheld by defendant where plaintiff sought a legal, not equitable, remedy, and that, to the extent plaintiff sought to sanction defendant, this remedy was also not allowed under ERISA. The court also declined to use estoppel principles to modify the unambiguous terms of an ERISA plan. The court further held that the district court did not err in granting plaintiff's motion for summary judgment where defendant lacked standing to prosecute its cross-appeal where defendant was not aggrieved by a judgment requiring it to pay an amount that it always agreed that it owed and where defendant already refunded the premiums.