Justia Insurance Law Opinion Summaries

Retirees filed suit in district court contending that their retiree health benefits were vested and that defendant's intended modification would violate both the Labor Management Relations Act, 29 U.S.C. 185, and the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)(B). Retirees subsequently appealed the denial of their motion for a preliminary injunction seeking continuation of certain healthcare benefits. The court held that the district court issued a thorough and well-reasoned opinion explaining in detail that the retirees failed to establish a likelihood of success on the merits. Accordingly, the court affirmed the district court's denial of the motion for preliminary injunction.

This case stemmed from the collective bargaining agreement (CBA) between Volvo Group North America, LLC (Volvo) and the union representing workers at Volvo's New River Valley assembly plant (NRV). At issue was whether the CBA permitted Volvo to make unilateral changes to the health benefits of retirees from its NRV assembly plant after the agreement expired. The court held that Volvo was not permitted to make unilateral modifications to the retirees' health benefits after the expiration of the CBA unless it followed the mechanism agreed to by both parties in that agreement. Therefore, the court affirmed the judgment of the district court where Volvo could not employ that mechanism in this case.

Plaintiff sued defendant alleging breach of fiduciary duty and sought damages under the "other appropriate equitable relief" provision of the Employee Retirement Income Security Act ("ERISA"), 29 U.S.C. 1132(a)(3), where defendant denied plaintiff's life insurance coverage claims for her deceased daughter on the grounds that her daughter did not qualify for coverage under the plan's "eligible dependent children" provision. At issue was whether section 1132(a)(3) allowed the remedy of surcharge, which would permit recovery of the life insurance proceeds lost by plaintiff because of defendant's breach of fiduciary duty. Also at issue was whether the court should recognize equitable estoppel as part of the common law of ERISA. Further at issue was whether the district court erred in granting plaintiff's motion for summary judgment. The court held that the remedy of surcharge was not available under section 1132(a)(3) and that the district court did not err in limiting plaintiff's damages to the premiums withheld by defendant where plaintiff sought a legal, not equitable, remedy, and that, to the extent plaintiff sought to sanction defendant, this remedy was also not allowed under ERISA. The court also declined to use estoppel principles to modify the unambiguous terms of an ERISA plan. The court further held that the district court did not err in granting plaintiff's motion for summary judgment where defendant lacked standing to prosecute its cross-appeal where defendant was not aggrieved by a judgment requiring it to pay an amount that it always agreed that it owed and where defendant already refunded the premiums.

Appellants appealed an order revoking their pro hac vice admissions in connection with a putative class action suit where the suit alleged that appellants' clients breached supplemental cancer insurance policies that they had issued. At issue was whether the district court erred in revoking appellants' pro hac vice status where the revocation was based on motions appellants filed in response to plaintiffs' request for class certification, chiefly a motion to recuse the district judge based on his comments during an earlier hearing. The court vacated the revocation order and held that, even though the recusal motion had little merit, the district court erred in revoking appellants' pro hac vice admissions where it did not afford them even rudimentary process.