Employee Benefits

Dist. Ct. erred in granting on limitations grounds defendants’ motion for summary judgment in ERISA action alleging that defendants-Plan trustee and fiduciaries breached fiduciary duty owed to plaintiffs(employees in employee stock ownership plan) arising out of defendants’ involvement in company stock buy-out plan that ultimately left plaintiffs’ stock in said company worthless. Although defendants argued that plaintiffs’ knowledge of substantive terms of buy-out plan triggered applicable three-year limitation period so as to render instant lawsuit untimely, Ct. found that instant lawsuit was timely, where limitations period was not triggered until plaintiffs had knowledge of processes used by defendants to evaluate, negotiate and ultimately approve agreement not to sell off employees’ stock in ill-fated buy-out plan.

In action alleging that defendant-employer interfered with plaintiff-employee’s FMLA rights by denying him FMLA leave after January 1, 2008, by failing to provide him with timely notice that his FMLA leave had been exhausted, and by requiring him to pay for his medical premiums after his FMLA leave had been exhausted, record contained sufficient evidence to support jury’s verdict in favor of defendant, as well as Dist. Ct.’s grant of plaintiff’s Rule 50 motion for judgment n.o.v. with respect to medical premiums that plaintiff was required to pay for month of January 2008. While defendant objected to Dist. Ct.’s grant of instant Rule 50 motion, defendant failed to challenge Dist. Ct.’s ruling that plaintiff was entitled to FMLA leave, and defendant otherwise conceded that plaintiff’s FMLA leave lasted until January 31, 2008. Thus defendant should not have garnished plaintiff’s wages to recover medical premiums for month of January of 2008. Moreover, Ct. rejected defendant’s claim that, in spite of its concession, it was entitled to contest various specific requests for FMLA leave on grounds that plaintiff’s wife was not experiencing qualified medical condition at time of said requests.

Dist. Ct. did not err in holding defendants in civil contempt for failing to place $180,000 in settlement proceeds in defendant-lawyer’s client account pending final judgment in ERISA action filed by plaintiff-health plan seeking recovery of said proceeds for payment of medical bills that plaintiff had made on behalf of another defendant for injuries that formed basis of $500,000 settlement that said defendant had received in underlying personal injury action. Plaintiff’s claim to disputed proceeds was in essence subrogation lien, and defendants could not claim that plaintiff was not entitled to said proceeds, even though defendants contended that $500,000 settlement was payment solely for “post-accident tortious conduct,” where settlement agreement indicated that settlement covered all claims that could have been asserted in underlying action. Moreover, defendant could not avoid contempt order by merely stating that neither had disputed settlement funds, and record otherwise showed that neither defendant had provided current information on all of their assets/client accounts.

Record failed to support ALJ’s denial of claimant’s application for Social Security disability benefits, where said application alleged inability to work on account of claimant’s sciatica, angina, degenerative disc disorder, fibromyalgia and diabetes. While ALJ found that claimant retained ability to perform light work in spite of her impairments, ALJ ignored medical evidence that supported claimant’s complaints of severe pain. Moreover, ALJ failed to consider combined effects of claimant’s ailments and made factual error regarding claimant’s use of her thumb.