The case involved the United States seeking to recover the balance on defaulted federally guaranteed student loans that the defendant obtained between 1971 and 1975. After the defendant defaulted, the Department of Education paid the guaranty claim, took assignment of the notes, and applied credits including tax refund offsets, leaving a balance of $3,824.82 as of August 1992. The court granted the government's motion for summary judgment, holding that the Higher Education Technical Amendments Act of 1991 eliminated any statute of limitations for collecting such loans and expressly revived time-barred claims in pending cases. The decision rested on the conclusion that Congress has authority to modify or eliminate statutes of limitations for federal debts without violating constitutional rights, and that the defendant's asserted defenses did not create a genuine issue of material fact.
This ERISA case involved an employee health insurance plan administered by Blue Cross and Blue Shield of Alabama, under which the McDaniels sought coverage for a hysterectomy performed in April 1987. Blue Cross had issued a pre-admission certification letter approving the procedure but later denied the claim on the ground that the condition was pre-existing and subject to a 270-day waiting period in the plan. The court applied an arbitrary-and-capricious standard of review because the plan granted the administrator discretionary authority, yet concluded that the denial was unreasonable. It found the pre-admission letter ambiguous and misleading in its assurances of coverage, creating confusion that had to be construed against the drafter. The court therefore entered judgment for the plaintiffs and awarded the claimed benefits plus interest and attorney fees.
This case involved an ERISA claim by the McDaniels against Blue Cross and Blue Shield of Alabama for denying health insurance benefits for a hysterectomy on the grounds that it was a pre-existing condition not covered under the 270-day waiting period. The court denied the defendant's motion for summary judgment and ruled that the plaintiffs were entitled to benefits of $5,016.80. The court applied the arbitrary and capricious standard of review, adjusted for Blue Cross's conflict of interest as both administrator and payer, and found that Blue Cross breached its fiduciary duty by approving the pre-admission certification without properly reviewing eligibility or medical records beforehand.
The case involved a wrongful death claim under the Death on the High Seas Act brought by Sheryl Galik, as administratrix of her husband's estate, against Lockheed Shipbuilding Company. Galik alleged that her husband, a Coast Guard technician, died from injuries sustained when he was thrown during a storm on the icebreaker POLAR SEA due to insufficient handrails near the fathometer in the pilothouse. Lockheed moved for summary judgment, asserting the government contractor defense. The court granted the motion after finding that the Coast Guard had approved reasonably precise design specifications for the vessel, that Lockheed had built the ship in conformity with those specifications, and that any known dangers had been apparent to the Coast Guard, satisfying all three prongs of the defense established in Boyle v. United Technologies Corp.
This ERISA case involved plaintiffs Vivion and Paulette McRae, who sought coverage under an employee welfare benefit plan administered by the Seafarers’ Welfare Plan for a tubal reanastomosis surgery. The McRaes' doctor's office verified coverage for the procedure via the plan's toll-free line, and the McRaes proceeded with the surgery in reliance on that verification; the plan initially paid some related bills but later denied coverage and sought reimbursement. The court found that the telephone verification bound the plan to provide coverage for the entire procedure. It ruled that the plan must pay the outstanding medical expenses totaling $6,340.69, awarded the plaintiffs $50,000 in extra-contractual damages, and granted attorney fees based on the plan's bad faith in reversing its coverage determination after the surgery occurred.
This admiralty case concerned a claim by fuel supplier John W. Stone Oil Distributor, Inc. for a maritime lien of $9,688.63 against the vessel M/V MISS BERN after it was sold to new owner Glenn Towing, Inc. The court found that Stone had furnished the fuel and oil and that a maritime lien had attached, but held the lien unenforceable because Stone's failure to record a notice of claim of lien or pursue collection promptly constituted laches that prejudiced the innocent subsequent purchaser without notice. The court further concluded that the vessel's arrest was not wrongful, as Stone was entitled to judicial determination of the lien's validity, and that Glenn Towing had not proven any damages from the seizure. Judgment was entered denying enforcement of the lien against the vessel while rejecting the counterclaim for wrongful seizure.