This case involved an employee suing his former employer after termination, claiming violation of Missouri's service letter statute for failing to provide required documentation of employment (Count I) and a prima facie tort for discontinuing medical insurance coverage (Count II), which the defendant removed to federal court under ERISA. The court denied the defendant's motion for summary judgment on Count I, as a genuine factual dispute existed over whether the employer had seven or more employees when the claim arose. It granted partial summary judgment on Count II on grounds of ERISA preemption, ruled that no jury trial was available for that count, denied the defendant's motion to strike a filing, and denied the plaintiff's discovery motions for not complying with local rules requiring good-faith conferral efforts.
The case involved Lucille Fogerty's 1986 lawsuit against Metropolitan Life Insurance Company seeking disability benefits under a group insurance plan sponsored by her former employer, General Electric, which she claimed entitled her to payments from late 1976 onward after her benefits were terminated. The plan was governed by ERISA, but because ERISA lacks its own statute of limitations, the court applied Missouri law. Defendant moved to dismiss on the ground that the claim was untimely, and the court granted the motion, holding that the five-year limitations period for contract actions applied rather than the ten-year period for writings for the payment of money. The core reasoning was that the insurance plan was a contract for services, not an acknowledgment of indebtedness on its face, so establishing liability required extrinsic proof such as the extent of the plaintiff's disability.
In Holcomb v. United Automotive Ass'n of St. Louis, a beneficiary of a pension plan established by a union and employer association sued to challenge the trust indenture's trustee selection and removal rules, claiming they violated ERISA fiduciary duties and the equal-representation requirements of section 302(c)(5)(B) of the LMRA. The district court granted summary judgment to defendants on the ERISA claim, holding that provisions allowing removal of union trustees only for cause did not create a structural conflict with fiduciary obligations. On the LMRA claim the court granted summary judgment to the plaintiff, concluding that the indenture's asymmetric removal rules denied the union equal authority to appoint and remove its trustees, contrary to the statute's parity mandate. The court therefore ordered the offending sections stricken and directed that each side could remove and replace its designated trustees at any time.
The case involved St. Louis Federal Savings and Loan Association seeking recovery of $10,000 in audit expenses under a savings and loan blanket employee fidelity bond issued by Fidelity and Deposit Company of Maryland, after an audit prompted by alleged misconduct by former president Emmett Capstick. The Association had previously settled a wrongful dismissal suit with Capstick and executed a broad release of all claims against him, before notifying the insurer of its bond claim. Applying Missouri law in this diversity action, the court granted directed verdicts for the defendant insurer against the Association and for Capstick against the insurer's third-party subrogation claim, holding that the pre-claim release without the insurer's consent impaired its subrogation rights and thereby barred recovery under the bond.
This case involved a dispute over a $12,574.13 surplus from the foreclosure sale of the Jordans' property under a first deed of trust. The Small Business Administration, as holder of a second deed of trust securing a defaulted business loan, and the Jordans, who had received a bankruptcy discharge, both claimed the surplus after the sale. The court granted the SBA's motion for summary judgment. It reasoned that junior lienholders take priority over the mortgagors for any surplus proceeds, the bankruptcy discharge did not extinguish the SBA's secured interest in the property, and the terms of the first deed of trust could not override the SBA's rights as a junior lienholder.
This case concerns Medicare health care providers seeking reimbursement for malpractice insurance premiums allocable to Medicare patients, following an earlier court order that invalidated the Malpractice Rule and required use of prior regulations. The Secretary of Health and Human Services moved for partial relief from that order as to St. Francis Hospital and St. Mary's Health Center, asserting lack of subject matter jurisdiction because those providers filed untimely appeals with the Provider Reimbursement Review Board and the Board denied their requests for good cause exceptions. The court granted the motion, ruling that the 180-day filing deadline under 42 U.S.C. § 1395oo(a) is a jurisdictional prerequisite that cannot be waived and that the Board has exclusive authority to grant or deny extensions, leaving no reviewable final decision. The court also denied the providers' motion to remand those claims and the Secretary's request for an extension of time to appeal or entry of a new final judgment.