Justia U.S. 9th Circuit Court of Appeals Opinion Summaries

Plaintiffs, former employees of Golden Eagle, filed a class action against Liberty Mutual for violating the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs alleged that when Liberty Mutual purchased Golden Eagle, Liberty Mutual told plaintiffs that they would receive past service credit for the time they worked with Golden Eagle under Liberty Mutual’s retirement plan. The district court granted summary judgment to Liberty Mutual. The court concluded that plaintiffs cannot receive benefits for past service credit with Golden Eagle under the terms of the retirement plan where the district court applied the correct abuse of discretion standard, and Liberty Mutual's interpretation of the plan was reasonable. The court also concluded that plaintiffs are not barred from bringing simultaneous claims under section 1132(a)(3) and 1132(a)(1)(B). In Varity Corp. v. Howe, equitable relief under section 1132(a)(3) is not available if section 1132(a)(1)(B) provides an adequate remedy. In CIGNA Corp. v. Amara, section 1132(a)(3) authorized equitable relief in the form of plan reformation, even though plaintiffs also claimed relief under section 1132(a)(1)(B). Applying Amara’s conclusion that a plaintiff may seek relief under both section 1132(a)(1)(B) and section 1132(a)(3) does not contravene the ruling in Varity. The court further concluded that Liberty Mutual failed to notify plaintiffs in its summary plan descriptions that past service credit with Golden Eagle would not count for benefits accrual, but plaintiffs did not prove harm or reliance on the summary plan descriptions. Finally, the class certification was appropriate. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Moyle v. Liberty Mut. Ret. Benefit Plan" on Justia Law

Bruce Barton filed suit against ADT under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1132, seeking claims related to his request for pension benefits. On appeal, Barton challenges the district court's conclusion that the Plan Administrator did not abuse its discretion in denying Barton’s request for pension benefits. The court concluded that the district court incorrectly placed the burden of proof on Barton for matters within defendants’ control. The court held that where a claimant has made a prima facie case that he is entitled to a pension benefit but lacks access to the key information about corporate structure or hours worked needed to substantiate his claim and the defendant controls such information, the burden shifts to the defendant to produce this information. The district court correctly held that to recover statutory penalties based on a plan administrator’s refusal to comply with ERISA’s disclosure obligations, a plaintiff must qualify as a plan participant. The court reversed and remanded for the district court to apply the now-clarified burden of proof in this case. View "Estate of Barton v. ADT" on Justia Law

After a bench trial, the district court held that Michael's was not liable as a successor employer by weighing continuity of the workforce as the most important factor. At issue was: (1) whether a successor employer, both generally and in the construction industry in particular, can be subject to withdrawal liability under the Multiemployer Pension Plan Amendments Act (MPPAA), 29 U.S.C. 1381–1453, amendments to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq.; and (2) if so, what factors are most relevant to determining whether a construction industry employer is a successor for purposes of imposing MPPAA withdrawal liability. The court concluded that a construction industry successor employer can be subject to MPPAA withdrawal liability, so long as the successor took over the business with notice of the liability; that the most important factor in assessing whether an employer is a successor for purposes of imposing MPPAA withdrawal liability is whether there is substantial continuity in the business operations between the predecessor and the successor, as determined in large part by whether the new employer has taken over the economically critical bulk of the prior employer’s customer base; and, in this case, the district court erred in weighing continuity of the workforce as the most important factor and applying an incorrect test to determine whether there was continuity of the workforce. Accordingly, the court reversed and remanded for further proceedings. View "Resilient Floor Covering Pension Trust Fund Bd. of Trs. v. Michael's Floor Covering" on Justia Law

OTET appealed the district court's grant of summary judgment for Hillsboro Garbage, Robert Henderson, and the Estate of Darrol Jackson. The district court granted summary judgment in favor of defendants on (1) OTET’s breach of contract claims because the district court found those claims to be preempted by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq.; and (2) OTET’s restitution and specific performance claims because the district court concluded that those claims were not cognizable under ERISA as they sought legal - not equitable - relief. The court concluded that the district court properly dismissed the common law breach of contract claims as preempted by ERISA; the district court properly dismissed the restitution and specific performance claims where recent circuit precedent does not support OTET's argument; and the district court did not abuse its discretion in denying OTET the right to file a third amended complaint where OTET was given two opportunities to amend its complaint and unilaterally decided to eliminate the fraud count and it does not contend that it acquired any knew knowledge or that any misconduct occurred. Accordingly, the court affirmed the judgment. View "OR Teamsters Emp'ers Trust v. Hillsboro Garbage Disposal" on Justia Law

Plaintiff filed suit against National Union under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., which permits a beneficiary of an employee benefit plan to bring a civil action to recover benefits owed under the plan. Plaintiff claimed that her husband's death occurred as a result of an accident as defined by the policy. Plaintiff's husband died as a result of Deep Vein Thrombosis (DVT) shortly after he completed roughly 28 hours of air travel in a five-day period. The court concluded that regardless of whether the husband's death may be characterized as an externally caused “accident” when considering that word in isolation, his loss of life was not within the policy’s coverage. His fatal injury did not directly result from an unintended and unanticipated happening “external to the body.” Accordingly, the court affirmed the district court's grant of summary judgment for National Union. View "Williams v. Nat'l Union Fire Ins." on Justia Law

Plaintiff filed suit against AETNA under the civil enforcement provision of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132. AETNA had denied plaintiff's application for continued long-term disability benefits and allowed plaintiff to file an internal appeal within 180 days. The district court dismissed the action for failure to exhaust administrative remedies. The court reversed, holding that because the last day of the appeal period fell on a Saturday, neither that day nor Sunday count in the computation of the 180 days. In this case, because plaintiff mailed his notice of appeal on Monday, it was timely. The court concluded that this method of counting time is widely recognized and furthers the goals and purposes of ERISA. and therefore, the court adopted it as part of ERISA’s federal common law. View "LeGras v. AETNA Life Ins. Co." on Justia Law

After a series of unsuccessful appeals to an ERISA plan administrator after the administrator’s decision to deny him long-term disability benefits, Plaintiff brought this action under 29 U.S.C. 1132(a)(1)(B). The district court affirmed. The Ninth Circuit vacated the district court’s judgment, holding that the district court erred in reviewing the denial of benefits for an abuse of discretion, rather than de novo, when a Summary Plan Description conferred discretionary authority upon the plan administrator but an insurance certificate, a governing plan document, did not. Remanded for the district court to review the plan administrator’s denial of benefits de novo. View "Prichard v. Metro. Life Ins. Co." on Justia Law

This case arose out of a disability benefits dispute between Plaintiff, a retired firefighter for the City of Tracy, California, and the California Association of Professional Firefighters (CAPF), the manager of an employee welfare benefit plan. While a related action was ongoing, Plaintiff initiated a second lawsuit against CAPF, California Administration Insurance Services, Inc. (CAISI), and individual members of the board of directors for both CAPF and CAISI, alleging that Defendants had breached their fiduciary duties under ERISA in the management and administration of the plan. A panel of the Ninth Circuit affirmed in part and reversed in part the district court’s judgment, holding that the district court (1) correctly granted summary judgment for Defendants on a claim that they breached their duty to hold plan assets in trust; (2) erred in granting summary judgment for Defendants on a claim that they breached their fiduciary duties by engaging in unlawful self-dealing; and (3) erred in granting partial summary judgment for Plaintiff where Defendants did not breach their fiduciary duties by failing to distribute a summary annual report. Remanded. View "Barboza v. Cal. Ass’n of Prof’l Firefighters" on Justia Law

Before his retirement, Asa Williams, Sr. participated in various benefit programs (the Xerox Plans), which are subject to the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Asa married Carmen and designated Carmen as his beneficiary. After their divorce, Asa attempted to change his designated beneficiary from his ex-wife to his son (Asa, Jr.). After Asa, Sr.'s death, Carmen claimed to be the beneficiary under the Xerox Plans and Asa, Jr. likewise asserted the same claim. Carmen subsequently moved for summary judgment, asserting that because Asa, Sr. failed to fill out and to return the beneficiary designation forms, he did not properly designate Asa, Jr. as beneficiary in her place. The district court granted the motion. The court concluded that the district court erred in determining that Asa, Sr. was required to abide by the language contained in the forms - but not in the governing plan documents - to change his beneficiary from Carmen to Asa, Jr. Reviewing de novo whether Carmen or Asa, Jr. is entitled to plan benefits, the court concluded that based on the evidence, including Xerox's call log reflecting that Asa, Sr. called Xerox to change his beneficiary designation from Carmen to Asa, Jr., a reasonable trier of fact could determine that Asa, Sr. intended to change his beneficiary to Asa, Jr. and that his phone calls to Xerox constituted substantial compliance with the governing plan documents' requirements for changing his beneficiary designation. Accordingly, the court reversed and remanded. View "Mays-Williams v. Williams" on Justia Law

United is the claims administrator for Plans named as defendants in this suit and all of the Plans are governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Spinedex, as assignee and would-be assignee of Plan beneficiaries, filed suit against United and the Plans seeking payment of denied benefit claims. ACS, as well as individual Plan beneficiaries, Jack Adams and Claude Aragon, joined the suit as plaintiffs. The district court granted summary judgment to defendants. The court reversed, concluding that Spinedex had Article III standing; Spinedex was not assigned the right to bring claims for breach of fiduciary duty; ACS does not have associational standing to bring suit against United; Adams' claim for breach of fiduciary duty is time-barred; Spindex's claims as assignee of beneficiaries under the Martz Agency Plan and the Acoustic Technologies Plan are not time-barred; and the anti-assignment provision of the Discount Tire Plan precluded assignment by Plan beneficiaries to Spinedex. The court vacated or reversed, and remanded for further proceedings, the district court's holdings that Aragon's claim for breach of fiduciary duty was not exhausted, that United is not a proper defendant for benefit claims under the American Express Plan, and that some of the claims assigned to Spinedex were not administratively exhausted. View "Spinedex Physical Therapy v. United Healthcare" on Justia Law