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

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

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

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

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

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

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

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

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

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.

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.