On this page, we will add recent and notable ERISA case decisions as we come across them.
RECENT KEY CASES
- Cigna v. Humble Surgical Hospital – June 2016- Southern District of Texas issued a verdict of $13.7 million against Cigna in part due to a breach of fiduciary duty and bad faith.
- O’Shea v. UPS Retirement – September 2016 – First Circuit case where the Court ruled that a Plan does not have to pay benefits if an employee passed away prior to his retirement date/annuity start date.
- Deschamps v Bridgestone Americas, Inc Salaried Employees Retirement Plan No. 15-6112 – September 2016 – Sixth Circuit Court of Appeals case where the Court ruled in favor of the Plaintiff who asked that the Court restore his original hire date. Deschamps started working for Bridgestone in Canada transferred to the U.S. branch after working there for ten years. Subsequently, he did not want to lose ten years of pension benefits he has accrued.
- Solnin v. Sun Life and Health Insurance Company – October 2008 – Eastern District of New York case where the Court ruled that surveillance video of Ms. Solnin’s daily activities, amassed over the course of 10 years, proved she was honest in regard to the limitations she provided to her insurance company, disabled and entitled to her long term disability benefits.
- Fort Halifax Packing Co., Inc. v. Coyne, 482 U.S. 1 (U.S. 1987) – The Supreme Court held that ERISA did not preempt Maine Statute, and in the decision, the Court provided guidance as to how ERISA preemption could be triggered. Established the definition of what is an employee benefit plan.
- Firestone Tire & Rubber Co. Et Al. v. Bruch Et Al., 489 U.S. 101 (1989) – The Supreme Court Held that a de novo standard of review applies for evaluating participant benefit claim lawsuits unless the plan specifically provides discretionary authority for the administrator or other plan fiduciary to clarify any ambiguities, provide an interpretation of the plan and resolve any benefit conflicts. If the language is included, and the administrator or fiduciary acted properly in accordance with the language, the Court held that the Court must look to see if the administrator/fiduciary acted unreasonably or arbitrarily, or was operating under a material conflict that affected the administrator’s / fiduciary’s decision.
- Lockheed Corp. et al. v. Spink, 517 U.S. 882, 894 (1996) – The Supreme Court held that it was not a violation of ERISA section 406(a)(1)(d) for employers to condition the payment of benefits predicated on the employee(s) executing a release of rights and claims related to employment.
- Cigna Corp. Et Al., v. Amara Et Al. 563 U.S. 421 (2011) – In this landmark Supreme Court Decision, the Court held, among other things, that (1) when there is a breach of trust by a fiduciary; (2) there is actual harm suffered by the beneficiary; and (3) the breach caused the harm, the plaintiff is entitled to a “Surcharge” or monetary relief under ERISA section 502(a)(3). The Court also held that section 502(a)(1)(b) claims are severely limited and also changed how the Court views Standard Plan Descriptions (SPD).