In this ERISA case, plaintiff Cindy Hansen, an employee covered by her employer's health plan administered by Actuarial & Employee Benefit Services Co., sought reimbursement for gastric bypass surgery performed to treat her severe GERD after medical therapy failed. The plan denied the claims citing an exclusion for obesity treatments, even though medical providers had determined the procedure was medically necessary for GERD and noted it would also address her obesity. The court granted summary judgment to Hansen, holding that the surgery was covered because it was directed at a qualifying condition and the denial was arbitrary under the abuse of discretion standard applied to the plan administrator's decision. The opinion emphasizes that the obesity exclusion does not bar coverage when the primary purpose is treating another illness and notes the lack of timely written denial or appeal information provided to Hansen.
This case involves a claim under the Age Discrimination in Employment Act (ADEA) by plaintiff Daniel L. Sloat, a machine tool instructor at Western Dakota Technical Institute, after the school district did not renew his one-year contract when it eliminated the second-year program due to low enrollment below the 15-student threshold needed for state funding. The district moved for summary judgment, arguing the decision stemmed from budget constraints and enrollment shortfalls rather than age, while Sloat sought to amend his complaint and contended the reasons were pretextual. The court granted summary judgment to the district, finding Sloat failed to establish a prima facie case of age discrimination or show that the legitimate nondiscriminatory reasons were pretext under the McDonnell Douglas burden-shifting framework, with no evidence linking the nonrenewal to age-based animus. The motion to amend was also denied as it would not alter the outcome. The ruling relied on undisputed facts about program funding, enrollment data, and the absence of any age-related statements or differential treatment tied to age.
This case involved a former employee suing her restaurant employer and related parties under Title VII for alleged sexual harassment by coworkers, including unwelcome comments, touching, and an alleged rape, along with a related state law claim against a manager; the plaintiff also alleged she was not promoted or otherwise harmed due to the conduct. The court granted the defendants' motion for summary judgment and dismissed the case with prejudice. The state claims were barred by South Dakota workers' compensation exclusivity rules. The Title VII claim failed because there was no tangible adverse employment action, vicarious liability did not attach, and the employer satisfied the Faragher affirmative defense through its anti-harassment policies and prompt corrective action on other complaints, which the plaintiff had not properly utilized.
The case involved Eleanor Big Owl, a teacher at Porcupine Day School on an Oglala Sioux reservation, who sued the United States under the Federal Tort Claims Act for intentional and negligent infliction of emotional distress. She alleged that the new school board violated its own handbook rules by failing to notify her by April 1, 1993, that it was contemplating non-renewal of her contract and by later informing her in June 1993 that she would not be rehired for the next year, causing her shock, stress, and sleeplessness. The court granted the defendant's motion for summary judgment and dismissed the claims with prejudice. The core reasoning was that employment decisions like contract renewal involved the exercise of discretion in furtherance of educational policy goals, triggering the discretionary function exception to the FTCA and depriving the court of subject matter jurisdiction; alternatively, the alleged conduct was not extreme and outrageous under South Dakota law and the plaintiff alleged no physical injury to support a negligent infliction claim.
The case concerned a trade association for South Dakota banks that sued its former group insurer over an alleged failure to pay a policy surplus refund and related misconduct by an insurance agent, asserting seven state-law claims including breach of contract, negligence, and deceit arising from employee benefit policies. The defendant moved for summary judgment, contending that the federal Employee Retirement Income Security Act (ERISA) preempted the state claims. The court granted the motion, holding that ERISA's preemption clause supersedes state laws that relate to employee benefit plans. It further determined that the Act's savings clause for state insurance regulations did not preserve the common-law causes of action, following the two-step analysis from Pilot Life Ins. Co. v. Dedeaux that focuses on the nature of the claims themselves rather than their factual basis.
business & regulatorylabor & employmentfederal power
This case involved plaintiffs seeking to hold the United States liable under the Federal Tort Claims Act for alleged misfeasance by employees of the Crow Creek housing authority, claiming coverage under a provision of the Indian Self-Determination and Education Assistance Act. The court granted the defendant's motion to dismiss, finding no subject-matter jurisdiction due to lack of waiver of sovereign immunity. The reasoning was that the contracts at issue were entered into with the Department of Housing and Urban Development rather than the Department of Health and Human Services or the Department of the Interior, so they did not qualify as self-determination contracts under the Act. The court rejected arguments that the contracts could have been authorized or that BIA involvement made them applicable, emphasizing that waivers of sovereign immunity must be strictly construed based on the statutory language.
