Justia Civil Procedure Opinion Summaries

From 1978-1997, Mathias worked for Caterpillar in York, Pennsylvania. In 1997 he experienced serious health issues; the Social Security Administration declared him disabled. Caterpillar covered his health insurance as an employee on long-term disability, billing him for his portion of the premium. In 2012 Mathias retired retroactively, effective October 2009. Caterpillar failed to change Mathias’s status and did not realize its mistake until 2013 when it notified Mathias that he owed $9,500 in past-due premiums, the difference between the rate for a long-term disabled employee and the rate for a retired employee. When Mathias did not pay, Caterpillar terminated his benefits. Mathias sued in the Eastern District of Pennsylvania. The plan documents require suit in the Central District of Illinois, so Caterpillar moved to transfer the case under 28 U.S.C. 1404(a). Mathias argued that the forum-selection clause was invalid in light of ERISA’s venue provision, 29 U.S.C. 1132(e)(2). The district court rejected that argument, relying primarily on Sixth Circuit precedent, holding that forum-selection clauses in ERISA plans are enforceable and not inconsistent with the text of ERISA’s venue provision. The case was transferred. Mathias petitioned for mandamus relief in the Seventh Circuit, which affirmed, holding that ERISA’s venue provision does not invalidate a forum-selection clause contained in plan documents. View "Mathias v. Mihm" on Justia Law

Plaintiff-appellee Elizabeth Cates filed on her behalf and a putative class asserting claims against the defendant-appellee INTEGRIS Health, Inc. for breach of contract, violation of the Oklahoma Consumer Protection Act, deceit, specific performance, and punitive damages. INTEGRIS successfully moved to dismiss the claims based on the ground that they are all preempted by the Employee Retirement Income Security Act. Cates appealed. Because the trial court in this matter did not take into consideration the federal Tenth Circuit Court of Appeals’ decision in Salzer v. SSM Health Care of Oklahoma Inc., 762 F.3d 1130 (10th Cir. 2014), which was factually similar to the facts of this case and found that the plaintiff’s claims were not preempted, the Oklahoma Supreme Court reversed and remanded the trial court in this matter for reconsideration in light of Salzer. View "Cates v. Integris Health, Inc." on Justia Law

Plaintiff and Henry married in 1987 and divorced in 1993. The Divorce Judgment granted Plaintiff one-half of the pension benefits Henry had accrued during the marriage, with full rights of survivorship. Henry was forbidden from choosing a payment option that would deprive Plaintiff of these benefits. Henry worked for Chrysler from 1965 to 1992, and began receiving retirement benefits in 1994, under a “Lifetime Annuity Without Surviving Spouse” option, in violation of the Judgment. Plaintiff’s attorney submitted the Judgment to the Plan administrator, who stated that the Judgment lacked information required by 29 U.S.C. 1056(d)(3)(C) to qualify as a “qualified domestic relations order,” so it could not override ERISA’s anti-alienation provision. Plaintiff did not contact the Plan again until after Henry had died in 2007. The Plan denied her benefits request, noting “the participant does not have a remaining benefit to be assigned.” For six years, Plaintiff unsuccessfully attempted to have the Plan qualify the Judgment. The Plan noted that changing the type of benefit was impermissible under plan the rules. In 2014, plaintiff obtained a nunc pro tunc order, correcting the Judgment. The Plan again denied benefits. Plaintiff filed suit under ERISA. The district court granted Plaintiff summary judgment, reasoning that, to the extent Plaintiff’s claim was based on the 2014, denial of benefits based on the Nunc Pro Tunc Order, it was timely and that the Order relates back to 1993. The Sixth Circuit reversed, finding the claim untimely. View "Patterson v. Chrysler Group, LLC" on Justia Law

Pension funds regulated by the Multiemployer Pension Plan Amendments Act, part of the Employee Retirement Income Security Act (ERISA), sued to collect shortfalls in contributions for 2003-2008 from System Parking, under four collective bargaining agreements with the union. The Seventh Circuit affirmed a judgment of $2,000,000, after concluding that it had authority to change the name on the judgment. The funds’ complaint and the judgment named, as defendant, the “L&R Group of Companies,” which is not a recognized business entity, organization, partnership, or trust; Fed. R. Civ. P. 17(a) states that suits must be conducted in the name of the real parties in interest. Rule 17(b) says that only persons or entities with the capacity to sue or be sued may be litigants. A “description” is not a juridical entity. System Parking’s assets were acquired by an entity not named in the complaint or served with process, so a motion to dismiss would have been granted, had the parties or the court been “paying attention.” With respect to the merits, the court upheld a finding that the employer’s audit was unreliable, having been prepared in-house, by a person without relevant experience, rather than by an independent accounting firm and being based on “murky” assumptions. View "Teamsters Local Union No. 727 v. L&R Group of Companies" on Justia Law

Central States is a self-funded Employee Retirement Income Security Act (ERISA) plan that provides health coverage to participating Teamsters and their dependents. The plan’s trustee sought a declaratory judgment concerning student athletes who had medical coverage under both the Central States plan and independent insurers’ policies. The trustee alleged that the plan paid the beneficiaries’ medical bills in full (about $343,000) and the insurers owe reimbursement. The plan and the insurers’ policies have competing coordination-of-benefits clauses, and each side claims that its respective provision makes the other primarily liable for the beneficiaries’ medical expenses (29 U.S.C. 1132(a)(3)). The Seventh Circuit affirmed dismissal of the case. ERISA section 502(a)(3) does not authorize suits of this type because the relief sought is legal, not equitable. View "Central States, Southeast & Southwest Areas Health & Welfare Fund v. American International Group, Inc." on Justia Law

ERISA Plaintiffs, administrators of Employee Benefit Plans governed by the Employees Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., who entered into securities lending agreements with Wells Fargo, seek to reverse the district court's judgment that it was bound by collateral estoppel and thus required to find against ERISA Plaintiffs and in favor of Wells Fargo on their ERISA claims. Other plaintiffs brought state common law claims. ERISA Plaintiffs and common-law plaintiffs were represented by the same law firm. Following the trial, the parties simultaneously submitted Proposed Findings of Fact and Conclusions of Law with respect to the ERISA claims. In its submission, Wells Fargo asserted that collateral estoppel should apply and that based on the jury verdict, the court was bound to find that there was no breach of fiduciary duty. The district court determined that it was constrained by collateral estoppel to render judgment on ERISA Plaintiffs’ claims consistent with the jury’s determination and issued judgment, dismissing the ERISA Plaintiffs’ ERISA claims with prejudice. ERISA Plaintiffs appeal, arguing that the district court erred in failing to find that Wells Fargo waived any right to assert that the district court was bound by the jury’s findings. The court vacated because the district court failed to consider whether the parties waived the application of collateral estoppel. The court remanded for the district court determine whether waiver occurred. View "Blue Cross Blue Shield of MN v. Wells Fargo Bank, N.A." on Justia Law

Trent Lebahn sued Eloise Owens, a consultant for Lebahn’s employee pension plan, for negligently misrepresenting the amount of his monthly retirement benefits. The district court dismissed Lebahn’s negligent-misrepresentation claim, concluding it was preempted by the Employee Retirement Income Security Act. Lebahn then filed an untimely Rule 59 motion, arguing preemption did not apply because Owens was not a fiduciary of the pension plan. The district court construed the untimely motion as one under Rule 60(b) and denied relief, reasoning that Lebahn’s argument regarding Owens’s fiduciary status had been raised too late. Lebahn appealed. The Tenth Circuit concluded it lacked jurisdiction to consider Lebahn’s challenge to the district court’s underlying judgment, so its review was limited to the district court’s denial of relief under Rule 60(b). Upon review, the Court found Lebahn did not demonstrate the district court abused its discretion in denying relief under Rule 60(b), and therefore the district court’s judgment was affirmed. View "Lebahn v. Owens" on Justia Law

Several multi-employer health and welfare funds filed this suit under the Employee Retirement Income Security Act seeking approximately $70,000 in alleged delinquent contributions. The assertedly delinquent employer, Con-Tech Carpentry, did not file an answer within the statutory period and was found in default. The district court subsequently entered a judgment in the funds’ favor and awarded damages. Con-Tech subsequently filed a Fed. R. Civ. P. 60(b) motion, which also invoked Fed. R. Civ. P. 55(c). The judge denied the Rule 60(b) motion. The Seventh Circuit affirmed, holding that because Con-Tech made a deliberate decision to disregard the pending suit, there was no reason for the district judge to excuse Con-Tech’s conduct in retrospect. View "Mid-Central Illinois Reg’l v. Con-Tech Carpentry, LLC" on Justia Law

In 2007, Durand filed an Employee Retirement Income Security Act, 29 U.S.C. 1001–1461 (ERISA) class action against her former employer and the pension plan it sponsors, challenging the projection rate used by the Plan to calculate the lump-sum payment Durand elected to receive after ending her employment at the Company in 2003. The Plan then used a 401(k)-style investment menu to determine the interest earned by members’ hypothetical accounts. Durand alleged that it impermissibly used the 30-year Treasury bond rate instead of the projected rate of return on her investment selections in the “whipsaw” calculation required under pre-2006 law. The Sixth CIrcuit reversed dismissal for failure to exhaust administrative remedies. Defendants then answered the complaint and raised defenses, including that the claims of putative class members “who received lump-sum distributions after December 31, 2003” were barred due to an amendment to the Plan that took effect after that date. Plaintiffs argued that the 2004 Amendment was an illegal reduction or “cutback” in benefits. The Sixth Circuit affirmed that the “cutback” claims were time-barred and did not relate back to the “whipsaw” claim asserted in the original class complaint. View "Durand v. Hanover Ins. Group, Inc." on Justia Law

Plaintiff, the executrix of her husband's estate, along with her husband's former business, Federal City, filed suit against Life Investors for conversion and tortious interference with a contract. On appeal, plaintiffs challenged the district court's dismissal of the complaint. The court concluded that this action is not barred by claim preclusion because the claims brought are not based upon the same cause of action as the prior suit. In this case, plaintiffs allege claims for conversion and tortious interference with contract against Life Investors because Life Investors removed over $400,000 from certain accounts to cover expenses above the alleged debt plaintiffs owed Life Investors. Life Investors removed these funds after the decision in the Maryland district court. The Maryland court never determined that plaintiffs lacked any interest in the assets in the accounts. Instead, it decided that plaintiffs were time-barred from bringing claims from a 2000 request for withdrawal of the assets and that the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., claims were either time-barred or failed to allege a violation of ERISA law. Similarly, the claim is not barred by issue preclusion. Accordingly, the court reversed and remanded. View "Corrado v. Life Investors Ins. Co." on Justia Law