This case involved an employee who worked as a machinist for twenty-two years and applied for disability retirement benefits under his employer's pension plan after claiming total and permanent disability due to back and neck pain. After initially approving the application, the employer denied benefits and terminated the employee upon reviewing surveillance video showing him performing strenuous physical activities on his farm, citing a violation of company rules against false reports or claims. The employee sued under ERISA, alleging breach of fiduciary duty and wrongful discharge to prevent attainment of benefits. The court granted summary judgment to the defendants, holding that the plaintiff failed to establish a prima facie case for wrongful discharge and that equitable relief under ERISA § 502(a)(3) was unavailable because § 502(a)(1)(B) provided an adequate remedy for any benefits due under the plan.
This case involved Blue Cross and Blue Shield of Alabama (BCBS), which administered a self-funded employee health benefits plan under ERISA for Nichols Research Corporation. BCBS paid $12,678.69 in medical expenses for plan participant Tina Sanders after she was injured in a car accident, but the Sanderses later obtained a $200,000 settlement from the at-fault parties without notifying BCBS or reimbursing the plan as required by its subrogation clause. BCBS sued in federal court to enforce the plan's subrogation and reimbursement provisions. The court granted summary judgment to BCBS and ordered the defendants to pay the full amount without any deduction for attorneys' fees. It reasoned that ERISA preempts Alabama's equitable subrogation rules because the plan is self-funded, the state law does not regulate insurance under the McCarran-Ferguson factors, and the deemer clause exempts such plans from state insurance regulation.
This case involved Blue Cross and Blue Shield of Alabama seeking a declaratory judgment that three Alabama statutes—the Assignment Act, Dental Act, and Pharmacy Act—were preempted by ERISA and that state law exempted Blue Cross from complying with them; intervening health care providers counterclaimed that Blue Cross violated the Dental and Pharmacy Acts. The court certified classes of providers and addressed threshold issues on motions for summary judgment. It held that ERISA preempts the three acts because they have a connection to and reference employee benefit plans governed by ERISA and do not qualify for the insurance saving clause, and that Alabama law separately exempts Blue Cross from the acts due to its enabling statutes. The court therefore granted Blue Cross partial summary judgment on the relevant counts.
This case is an interpleader action brought by Northwestern Mutual Life Insurance Company to resolve competing claims to the cash surrender value of eight life insurance policies purchased by City Federal Savings and Loan Association in connection with deferred compensation agreements and supplemental retirement income agreements for certain executives. After the Office of Thrift Supervision placed City Federal into receivership, the Resolution Trust Corporation as receiver demanded the policies' value as successor to the institution's general assets, while the former executives claimed the policies were subject to a constructive trust for their benefit. The court granted partial summary judgment to the Receiver, ruling that the agreements expressly made any such policies general, unpledged assets of City Federal rather than plan assets, that the plans were unfunded top-hat plans exempt from ERISA vesting and fiduciary rules, and that the claimants therefore held only unsecured creditor rights with no interest in the policies themselves.
The case involved the United States seeking reimbursement from Blue Cross and Blue Shield of Alabama for medical care and services provided to eight Medicare-eligible veterans with non-service-connected conditions at VA hospitals between 1987 and 1990. Each veteran held a Blue Cross Medigap policy, but the insurer denied the VA's claims on the ground that VA facilities do not participate in Medicare. The court held that 38 U.S.C. § 1729 requires Blue Cross to pay the VA the portion of costs (such as deductibles and coinsurance) that would have been covered if the care had been rendered in a participating private hospital. This conclusion followed from the statute's definition of a health-plan contract, which includes Medigap policies, and its anti-discrimination provision that prevents contractual terms from blocking federal recovery. The court issued a declaratory judgment to that effect but did not calculate specific amounts owed.
The case involved Acceptance Insurance Company seeking a declaratory judgment regarding its obligations under an insurance policy issued to Jerry Schafner after his guard dog bit Alice Frazier. The court granted summary judgment to Acceptance, holding that Schafner's six-month delay in notifying the insurer of the incident and lawsuit relieved Acceptance of its duties to defend, cover, or indemnify him. Under Alabama law, timely notice is a condition precedent to coverage, and the delay here lacked a reasonable excuse, as Schafner had been advised of potential litigation.