Justia U.S. 5th Circuit Court of Appeals Opinion Summaries

Cigna filed suit against Humble seeking overpayments and Humble counterclaimed under the Employee Retirement Income Security Act (ERISA) and Texas state common law. The district court concluded that Cigna's claims and defenses failed as a matter of law, and awarded Humble damages and penalties. The Fifth Circuit held that the district court failed to apply the required abuse of discretion analysis; other courts have upheld Cigna's interpretation of its insurance plans; and there was substantial evidence supporting Cigna's interpretation. Therefore, the court reversed the district court's judgment. The court also held that Cigna was not a named plan administrator and reversed the district court's award of ERISA penalties against Cigna. The court vacated in part the district court's dismissal of Cigna's claims against Humble and vacated the district court's award of attorneys' fees, remanding for further consideration. View "Connecticut General Life Insurance Co. v. Humble Surgical Hospital, LLC" on Justia Law

Babin, employed by Quality, developed carpal tunnel syndrome and had several surgeries. Three months after he returned to work, his employment ended. Babin participated in Quality’s employee benefit plan, which provided short- and long-term disability benefits, governed by the Employee Retirement Income Security Act (ERISA). Babin submitted a short-term disability benefits application to Standard, Quality’s insurer. In February 2013, Standard denied Babin’s claim because it had not received a necessary form from Quality. Babin alleges that he provided that form to Quality, which failed to complete it. In February 2014, Babin’s counsel asked Quality for disability plan documents. Babin claims that Quality did not send those documents before he filed suit, that he believed that the short-term plan provided six months of benefits, and, had he known that the plan only provides three months of benefits, he would have applied for long-term benefits; Quality’s failure to produce the documents caused him to miss the window for long-term benefits. Babin filed suit 20 months after requesting the documents, alleging failure to produce documents and failure to pay benefits. The parties settled the denial-of-benefits claim. The court held that Louisiana’s one-year prescriptive period for delictual claims applies to 29 U.S.C. 1132(c) claims, so Babin’s claim was time-barred. The Fifth Circuit affirmed, rejecting Babin’s argument that Louisiana’s 10-year prescriptive period for personal actions should govern his claim for failure to produce documents. View "Babin v. Quality Energy Services, Inc." on Justia Law

The Fifth Circuit affirmed the district court's dismissal of plaintiff's claims, holding that the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132, preempted state law claims. The court held that, although the savings clause preserves a role for certain state laws that regulate insurance, state claims that provide a separate vehicle for seeking benefits from an ERISA plan remain preempted as such claims must be brought under ERISA's civil enforcement provision. The court explained that, otherwise, the exclusivity and uniformity of that federal remedy would be undermined. In this case, because plaintiff's claim for benefits must be brought under federal law, the district court correctly dismissed her state law claims seeking the same relief. Furthermore, the availability of that statutory remedy under section 502 of ERISA also defeated plaintiff's claim for equitable relief under federal law. View "Swenson v. United of Omaha Life Insurance Co." on Justia Law

This appeal concerned objections to the settlement of class actions that arose in the wake of a financial crisis involving SRHS and its benefits pension fund. The Fifth Circuit held that the terms of the Settlement Agreement as they affect Plan participants should have been more thoroughly examined prior to the district court's approval; the district court improperly limited its consideration to the hospital's ability to pay while ignoring a transparent explanation of the settlement's consequences for the class members; and thus the court vacated and remanded for further consideration of the enumerated issues. View "Jones v. Singing River Health Services Foundation" on Justia Law

After plaintiff settled a medical malpractice claim, the employee benefit plan organized under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., sought reimbursement. The Fifth Circuit held that when the plan paid for plaintiff's medical expenses, its summary plan description (SPD) can function as both an SPD and a written instrument; the SPD sufficiently complied with section 1102(b) by giving sufficient information regarding how the plan is funded or how it can be amended; when an SPD is a plan's only plausible written instrument, courts assume that the SPD is the written instrument; an SPD that defers to a non-existent plan document can be enforced as the plan's governing text; and the equities favor defendants in this case. The court also concluded that there was no abuse of discretion in issuing the award of attorneys' fees and costs. Accordingly, the court affirmed the district court's grant of summary judgment and fees and costs to defendants. View "Rhea v. Alan Ritchey, Inc. Welfare Benefit Plan" on Justia Law

After the BP Stock Fund lost significant value, the affected investors filed suit alleging that the plan fiduciaries breached their duties of prudence and loyalty by allowing the Plans to acquire and hold overvalued BP stock; breached their duty to provide adequate investment information to plan participants; and breached their duty to monitor those responsible for managing the BP Stock Fund. The district court held that the stockholders had failed to overcome the Moench v. Robertson presumption and dismissed their claims. The stockholders appealed, and while their appeal was pending in this court, the Supreme Court issued Fifth Third Bancorp v. Dudenhoeffer, holding that there was no such “presumption of prudence” under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. On remand, the district court held that the stockholders had plausibly alleged that defendants had inside information; and the stockholders had plausibly alleged two alternative actions that defendants could have taken that met the Fifth Third standard: freezing, limiting, or restricting company stock purchases; and disclosing unfavorable information to the public. The district court granted the motion to amend with respect to pleading these alternative actions. It then certified defendants’ motion for interlocutory appeal. The court concluded, however, that the district court here erred when it altered the language of Fifth Third to reach its holding. Under the Supreme Court’s formulation, the plaintiff bears the significant burden of proposing an alternative course of action so clearly beneficial that a prudent fiduciary could not conclude that it would be more likely to harm the fund than to help it. In this case, the stockholders have failed to do so. Because the stockholders' amended complaint is insufficient and the district court erred in granting their motion to amend, the court reversed and remanded. View "Whitley v. BP, P.L.C." on Justia Law

Plaintiffs, on behalf of themselves and others similarly situated, sought declaratory relief under section 502(a)(3) of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(3), injunctive relief, damages, attorney’s fees, and costs, against Berkshire and Acme. The district court granted defendants' motion to dismiss all claims. The court concluded that Acme did not violate the plans and did not breach its fiduciary duties when it adopted the amendment consistent with the plans’ terms and the law. Therefore, dismissal of plaintiffs' claims against Acme was appropriate. The court held that plaintiffs have pleaded sufficient facts to assert a plausible claim to relief against Berkshire. All of plaintiffs’ claims against Berkshire may proceed, except for its breach-of-contract claim that was not appealed and its participation in Acme’s breach-of-fiduciary-duty claim. Because the court found that plaintiffs did not plead sufficient facts to assert a plausible breach-of-fiduciary-duty claim against Acme, the court also found that the derivative participation claim fails against Berkshire. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Hunter v. Berkshire Hathaway" on Justia Law

Plaintiff filed suit against his former employer, Ericsson, asserting a claim under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Despite filing that federal claim in a federal forum, plaintiff alternatively sought declaratory relief that ERISA did not govern this dispute over the Severance Plans. The district court ruled that ERISA governed the case and later granted summary judgment for Ericsson. The court concluded that Ericsson’s Plans check off most of the factors indicative of ERISA plans, and thus plaintiff's suit seeking to obtain benefits available under them, are governed by the federal statute. On the merits, the court concluded that the district court did not err in ruling as a matter of law that the Plan allowed Ericsson to deny benefits on the ground that plaintiff failed to meet the return of property condition. Given the absence of language entitling plaintiff to severance pay based solely on the release of legal claims, it is not inconsistent with the Plan to impose other conditions reasonably related to the termination of the employment relationship. In this case, a provision requiring the return of property is in line with the overall terms of the Plans, which are aimed at providing severance to those who depart the company on good terms through no fault of their own. Accordingly, the court affirmed the judgment. View "Gomez v. Ericsson, Inc." on Justia Law

After Prudential denied coverage of a life insurance policy, plaintiff filed suit claiming that she had no notice of the exclusion for active-duty servicemen and that the exclusion is otherwise unenforceable. The district court granted summary judgment for Prudential and UPS. Plaintiff worked for UPS and participated in a plan which provides group insurance coverage to UPS employees. Plaintiff sought coverage after plaintiff's husband was killed in a weekend motorcycle accident while off base and not on duty. The court concluded that Prudential correctly interpreted the exclusion as barring the claim where the plan indicates that a spouse is not a qualified dependent when the spouse is on active-duty in the armed forces of any country. Moreover, it was not an abuse of discretion for Prudential to interpret the exclusion to apply regardless of whether a spouse was on military duty at the time of an occurrence. The court rejected plaintiff's claim that she was not on notice of the exclusion, concluding that the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., only requires the court to simply interpret the plan. The court rejected plaintiff's claims and affirmed the judgment. View "Singletary v. Prudential Ins. Co." on Justia Law

Plaintiffs, former employees of NOPSI, filed claims against RTA and others under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., and later 42 U.S.C. 1983 and various state laws. The district court granted summary judgment on the federal claims and declined to exercise supplemental jurisdiction on the state law claims. The court held that the plan at issue was a governmental plan and thus exempt from ERISA. Accordingly, the district court did not err in granting summary judgment as to the successor liability claims against the RTA. The court expressed no opinion as to whether successor liability applies to ERISA violations by predecessor entities. The court also concluded that plaintiffs' section 1983 claims are barred by the statute of limitations. Finally, plaintiffs failed to demonstrate that the district court abused its discretion in denying their FRCP 56(d) motion. Accordingly, the court affirmed the judgment. View "Smith v. Regional Transit Auth." on Justia Law