Justia Insurance Law Opinion Summaries

A non-profit hospital ("plaintiff") that provided medical services to beneficiaries of Local 272 Welfare Fund ("Fund"), an employee benefit plan governed by the Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. 1101, filed a complaint against defendants seeking payment for over $1 million in medical services provided to beneficiaries that the Fund had allegedly failed to reimburse. At issue was whether a healthcare provider's breach of contract and quasi-contract claims against an ERISA benefit plan were completely preempted by federal law under the two-pronged test for ERISA preemption established in Aetna Health Inc. v. Davila. The court held that an "in-network" healthcare provider may receive a valid assignment of rights from an ERISA plan beneficiary pursuant to ERISA section 502(a)(1)(B); where a provider's claims involved the right to payment and not simply the amount or execution of payment when the claim implicated coverage and benefit determinations as set forth by the terms of the ERISA benefit plan, that claim constituted a colorable claim for benefits pursuant to ERISA section 502(a)(1)(B); and in the instant case, at least some of plaintiff's claims for reimbursement were completely preempted by federal law. The court also held that the remaining state law claims were properly subject to the district court's supplemental jurisdiction.

Plaintiff sued defendant, National Union Fire Insurance Company of Pittsburgh ("National Union"), claiming disability benefits under the Employee Retirement Income Security Act of 1974 after a trip and fall injury. At issue was where plaintiff's presence at work precluded her from showing that she was disabled during that period and whether a reasonable factfinder could conclude that she was disabled within the meaning of National Union's plan. The court held that an employee's continued presence at her place of employment did not preclude a finding of disability when there was evidence that the employee was incapable of performing her job. The court also held that summary judgment in favor of defendant was improper when evidence presented by plaintiff indicated that there was a genuine issue of material fact where a reasonable factfinder could conclude that plaintiff was entitled to disability benefits under the plan.

Plaintiff, as a subrogee of a regional affiliate of the American Automobile Association Mid-Atlantic, Inc. ("AAAMA"), sued the liability insurers of the American Automobile Association ("AAA") seeking indemnification for payments made by plaintiff in settlement of a personal injury action. At issue was whether the district court erred in finding that AAAMA was an additional insured. The court held that the district court erred in finding that AAAMA was an additional insured where AAAMA's liability did not arise out of AAA national's operations.

Intervenors appealed an order granting plaintiffs' and defendants' joint motion for orders approving their Settlement Agreement and Mutual Release of Claims related to property damage claims that arose from the terrorist attacks of September 11th, 2001. At issue was whether the district court's application of New York state settlement rules was contrary to, and thus preempted by, the Air Transportation Safety and System Stabilization Act of 2001 ("ATSSSA"). Also at issue was whether the district court failed to make a proper evaluation of the fairness of the settlement agreement, and that the court erred in crediting the proposed settlement payments to the contributing defendants' respective liability limits under ATSSSA. The court held that the ATSSSA did not preempt New York state's "first-come first served" settlement rule and that the proposed settlement payments pursuant to the settlement agreement properly reduced the contributing defendants' remaining liability under the ATSSSA's liability limits. The court also held that the district court did not abuse its discretion in finding that plaintiffs and defendants entered into their settlement in good faith.