Smith v. OSF HealthCare System

Federal 7th Circuit Court
Civil Court
Summary Judgment
Citation
Case Number: 
No. 18-3325
Decision Date: 
August 13, 2019
Federal District: 
S.D. Ill.
Holding: 
Vacated and remanded

Dist. Ct. abused its discretion in granting motion for summary judgment by defendant-hospital operated by religious non-profit organization in plaintiff-employee’s ERISA action seeking declaration that pension plans operated by defendants are not eligible for church exemption, and thus were covered under ERISA so as to require that said plans be adequately funded, where said order was entered despite plaintiff’s motion under Rule 56(d) to postpone summary decision so that plaintiff could complete additional discovery. Record showed that instant summary judgment motion was filed long before discovery was to close, and discovery sought by plaintiff was material to summary judgment issue regarding whether plan committees were “principal-purpose” organizations within meaning of ERISA. Ct. further noted that plaintiff established strong record of diligence in pursuing discovery that included generation of pending discovery disputes, and that additional discovery sought in plaintiff’s Rule 56(d) motion would not have been futile.