Legal News

Case Summaries

ERISA

[08/19] Gaeth v. Hartford Life Ins. Co.
An award of attorney's fees to claimant pursuant to a finding that plan administrator's termination of long term disability benefits was arbitrary and capricious because it was not supported by any medical evidence of claimant's physical condition is vacated and remanded for reconsideration where the district court erred in its analysis under two of the factors of the test set forth by Secretary of the Department of Labor v. King, 775 F.2d 666 (6th Cir. 1985).

[08/14] Crowell v. Shell Oil Co.
In a suit by former Pennzoil employees alleging that they were underpaid for the value of their retirement and savings plans when they were terminated upon acquisition of Pennzoil by defendants, summary judgment for defendants is affirmed where: 1) defendants' notices of removal to federal court were not defective; 2) the Letters of Agreement at issue were "benefit plans" subject to ERISA preemption, and were not excepted from ERISA as "excess benefit plans"; 3) the district court properly drew factual inferences in plaintiffs' favor before granting defendants' summary judgment motion; 4) the district court properly reviewed the plan administrator's decision under an abuse of discretion standard; and 5) the administrator's interpretation of the plan was a fair reading of the plan and was uniformly applied, and was therefore legally correct.

[08/08] Pell v. E.I. DuPont de Nemours & Co., Inc.
In an employee's suit claiming that defendant underpaid his pension benefits, a ruling awarding relief under ERISA is affirmed, and rulings regarding remedies are reversed where: 1) plaintiff had standing to sue under ERISA; 2) plaintiff was entitled to equitable relief under ERISA based on an equitable estoppel theory; 3) an injunction requiring future higher payments was a form of equitable relief authorized by ERISA, and did not rewrite or informally amend the pension plan; 4) a constructive trust could be imposed on defendant's plan funds to obtain restitution; and 5) plaintiff's adjusted service date must be calculated with reference to defendant's misrepresentations as to the correct date.

[08/08] Kouvchinov v. Parametric Tech. Corp.
In an employment-discrimination action brought by plaintiff against his former employer, summary judgment for defendants is affirmed where: 1) in the absence of some significantly probative evidence showing discriminatory intent, the district court did not err in entering summary judgment for the defendants on the ERISA discrimination claim; and 2) there is no cognizable evidence of actual malice to support plaintiff's claim that defendant tortiously interfered with an advantageous business relationship.

[08/07] Speciale v. Blue Cross & Blue Shield Assoc.
In an ERISA claim for long-term disability benefits, summary judgment for plaintiff is reversed where the administrator reasonably determined that plaintiff's fibromyalgia did not totally disable her.

[07/31] Franciscan Skemp Healthcare, Inc. v. Cent. States Joint Bd. Health & Welfare Trust Fund
In a suit for negligent misrepresentation and estoppel over defendant-benefit plan's refusal to pay for medical services provided by plaintiff-provider, denial of plaintiff's motion to remand to state court is reversed and dismissal of claims is vacated where, because the claims related to an alleged misrepresentation rather than a mere denial of benefits, and because the duties alleged to have been breached had a basis independent from the ERISA statute, the doctrine of complete preemption did not apply and there was no federal jurisdiction.

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Labor & Employment Law

[08/20] Hurlic v. S. California Gas Co.
In a suit against defendant-company and its pension plan alleging that company's amendment of the plan violated both ERISA and the California Fair Employment and Housing Act (FEHA), dismissal of the lawsuit is affirmed in part, reversed in part, and remanded where: 1) pension plans utilizing a so-called cash balance formula (cash balance plans) do not violate an anti-age discrimination provision of ERISA; 2) cash balance plans do not violate one of ERISA's "anti-backloading" provisions; 3) ERISA preempts plaintiffs' state law FEHA claim; but 4) plaintiffs' complaint adequately alleged that defendants violated ERISA's notice requirement.

[08/20] Prescott v. Higgins
In a claim of racial discrimination against defendant city, grant of summary judgment for defendants, denial of plaintiff's cross-motion for summary judgment, and denial of motion to alter or amend the judgment are affirmed over claims of error that: 1) selection criteria used by defendant resulted in a less than eighty percent success rate for African-American applications; 2) the selection criteria have had a disparate impact on African-American applicants; and 3) plaintiff was not compensated for serving as Acting General Foreman in 2002 when the then-General Foreman was out on sick-leave.

[08/20] Soto-Lebron v. Federal Express Corp.
In a matter brought by former employee against defendant FedEx following his termination, grant of FedEx's motion for judgment as a matter of law on the slander and libel claims is affirmed where: 1) the evidence introduced in support of the slander claim "does not rise to more than informal rumors" circulating among employees, for which FedEx cannot be held liable; and 2) there was sufficient evidence to support liability for libel. Case is remanded for new trial on damages for the libel claim where admission of irrelevant evidence tainted the jury's damage calculation and that taint was not cured by remittitur. Denial of defendant's motion for judgment as a matter of law on the intentional infliction of emotional distress claim is reversed where former employee-plaintiff did not introduce any evidence suggesting that a subsequent employer or potential employer treated him adversely as a result of the defamatory statements made by FedEx.

[08/20] Henry v. Milwaukee County
In a Title VII suit alleging sex discrimination and retaliation by defendant-employer for its policy of assigning some correction officers' shifts in single-sex juvenile detention facilities on the basis of sex, judgment for defendant is affirmed in part and reversed in part where: 1) sex-based assignments weren't reasonably necessary to achieve the facility's goals of privacy, security, and rehabilitation, and therefore an officer's sex could not be considered a bona fide occupational qualification that would except defendant from the requirements of Title VII; but 2) plaintiffs had not proven their harassment or retaliation claims.

[08/20] Buckley v. Mukasey
In an action under Title VII claiming race discrimination, sex discrimination, and retaliation stemming from plaintiff's employment as a special agent with the Drug Enforcement Administration, judgment as a matter of law for the government is vacated and remanded where: 1) district court's ruling on certain class action litigation evidence constituted an error of law and thus, an abuse of discretion; 2) the court erred in granting the government's Rule 50 motion on a failure-to-promote retaliation claim; and 3) plaintiff was entitled to a new trial on the claims that were, and which should have been, submitted to the jury in a 2006 trial.

[08/19] Vaughn v. Epworth Villa
In an action alleging that plaintiff was retaliated against by defendant for participating in the Equal Employment Opportunity Commission (EEOC) process, dismissal of the claim is affirmed where: 1) although plaintiff engaged in a "protected activity" when she submitted unredacted medical records to the EEOC; 2) however, defendant provided a legitimate and facially non-retaliatory reason for its decision to terminate her based on the violation of the organization's policies and procedures regarding confidentiality when without authorization, specifically because she provided unredacted medical records to the EEOC; 3) plaintiff failed to establish that the reason was pretextual; and 4) she did not produce direct evidence of retaliation.

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