Justia U.S. D.C. Circuit Court of Appeals Opinion SummariesArticles Posted in ERISA
James v. Int’l Painters, et al.
Plaintiff filed suit alleging that the International Plan denied him benefits to which he was entitled. The parties disputed whether plaintiff accrued enough credit under an earlier plan, the Local 963 Plan, which was later merged into the International Plan. On appeal, at issue was whether, because of the procedural irregularities in the administrator's handling of the claim, the district court should have applied a de novo standard of review. The court concluded that the district court applied the correct standard and affirmed the judgment, concluding that plaintiff had not alleged Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., violations that rose to a level requiring a more stringent standard of review. View "James v. Int'l Painters, et al." on Justia Law
Davis, et al. v. PBGC
Pilots appealed the grant of summary judgment to PBGC on their claims regarding pension benefits payable under the terminated Retirement Income Plan for U.S. Airways Pilots. The court concluded that it need not resolve the parties' contentions regarding whether the PBGC was entitled to deference under Chevron when it acts as the trustee in an involuntary retirement plan termination; regardless, Pilots' claims relating to the PBGC's interpretation of 29 U.S.C. 1344 and regulations must fail; the court need not decide the level of deference due to the PBGC's interpretation of the Plan provisions because Pilots have not demonstrated Article III standing for part of one claim and their other claims failed regardless of the standard; and the court need not decide whether the decision in Davis v. PBGC regarding Pilots' request for a preliminary injunction was the law of the case on the standard of review. Accordingly, the court affirmed the judgment of the district court. View "Davis, et al. v. PBGC" on Justia Law
Oakey v. US Airways Pilots Disability Income Plan
Appellant a former pilot for US Airways, sought benefits from a collectively-bargained pilot disability plan under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. On appeal, appellant challenged the district court's dismissal of his claim for lack of jurisdiction. The court affirmed the district court's dismissal because section 204 of the Railway Labor Act (RLA), 45 U.S.C. 151 et seq., vested in the "applicable adjustment board" exclusive jurisdiction over appellant's claim because it was grounded in the application and interpretation of a collective bargaining agreement. View "Oakey v. US Airways Pilots Disability Income Plan" on Justia Law
United Steel, et al. v. Pension Benefit Guaranty Corp.
In this case, participants in the Thunderbird Mining Company Pension Plan sought "shutdown" pension benefits. The PBGC, the government agency that administered pension termination insurance under Title IV of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001-1461, denied the participants' request. These early retirement benefits were triggered by a permanent shutdown of a plant and were payable to plan participants who met certain age and years-of-service requirements. The court held that the agency's determination was not arbitrary or capricious where the record provided sufficient support for the agency's judgment that a permanent shutdown had not occurred before Eveleth's pension plan was terminated on July 24th, 2003. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the agency. View "United Steel, et al. v. Pension Benefit Guaranty Corp." on Justia Law
Kifafi v. Hilton Hotel Retirement Plan, et al
Appellee, an employee and participant in Hilton's retirement plan, sued for violations under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Appellee alleged that the Plan's benefit accrual formula was impermissibly backloaded and that Hilton, the Plan sponsor and administrator, violated both ERISA and the Plan by failing to credit certain years of service when calculating employees' vested credit. The court affirmed the district court's finding, that the Plan was impermissibly backloaded and that Hilton failed to calculate participants' vesting credit properly, because the district court handled the case well within its discretion. View "Kifafi v. Hilton Hotel Retirement Plan, et al" on Justia Law
Pettaway v. Teachers Ins. and Annuity, et al.
After injuring her back in a car accident, plaintiff filed for and received long-term disability benefits from the insurance plan sponsored by her employer. Plaintiff brought suit pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), 42 U.S. C. 29 U.S.C. 1001 et seq., against her employer and the administrators and underwriters of her employer-sponsored long-term benefit disability insurance policy after the claims administrator of that plan determined that she no longer qualified for benefits. At issue was whether the district court properly granted defendants' motion for summary judgment, finding no violation of law. The court held that because defendants acted reasonably, the court concluded that defendants' termination of plaintiff's benefits complied with federal law. The court found none of plaintiff's procedural claims persuasive and held that the district court did not err when it held that defendants did not violate plaintiff's right to a full and fair review of her adverse eligibility determination. The court also rejected plaintiff's argument that the district court violated local rule 7(h) where plaintiff failed to make this argument before the district court. Accordingly, the court affirmed the judgment of the district court.