Employee Benefits

Dist. Ct. did not err in granting defendant-health-care plan's motion for summary judgment in ERISA action that challenged defendant's decision to amend health-care plan for plaintiffs-retirees that required plaintiffs to pay 100 percent of cost of health-care premium instead of 50 percent of said premiums and ended plaintiffs' ability to use sick-leave balances at end of employment to cover plaintiffs' portion of said premiums. Record showed that any sick-leave balances were not assets of plan for purposes of imposing liability under 29 USC section 1106(a)(1)(D), and Ct. rejected plaintiffs' claim that plan itself created vested rights for plaintiffs where language of plan reserved right to change required contributions or even eliminate health-care benefits. Moreover, Ct. found that defendant's decision to amend its healthcare plan was business decision and not legal question as to whether defendant may use its authority to change plan to retirees' detriment. (Partial dissent filed.)

Dist. Ct. erred in dismissing plaintiff's ERISA action alleging that defendant-employer was in default for failing to pay full amount of revised withdrawal liability assessment after defendant had announced intention to withdraw from multi-employer pension plan. Dist. Ct. improperly concluded that defendant's failure to exhaust its administrative remedies by submitting to arbitration dispute as to actual amount of revised assessment was immaterial under circumstances where plaintiff-plan had also not sought arbitration of said issue. Accordingly, defendant's failure to seek arbitration on revised assessment calculation and its failure to pay full amount of revised assessment constituted default and operated as forfeiture of its opportunity to dispute amount of revised assessment, as well as precluded Dist. Ct. from finding that plaintiff made wrong calculation in revised assessment.

Dist. Ct. erred in awarding plaintiff $6,625 in attorney fees under Equal Access to Justice Act as prevailing party in claim seeking social security disability benefits where plaintiff sought $25,200in fees based in part on requested $225 per hour rate. While record was ambiguous as to number of hours sought by plaintiff's counsel, Dist. Ct. could not reduce hourly rate to $125 statutory ceiling based on belief that supporting evidence contained in plaintiff's reply brief was submitted too late. On remand, though, plaintiff may attempt to justify higher rate (i.e. $170 per hour) on cost of living adjustment, but must also show that inflation has increased cost of providing adequate legal service to person seeking relief against govt.

Record failed to contain sufficient evidence to support ALJ's denial of claimant's application for Social Security disability benefits after discounting opinion of treating physician that claimant suffered from bipolar disorder that prevented her from working. Record contained evidence supporting treating physician's opinion, and ALJ's ruling demonstrated failure to understand nature of claimant's disability. Moreover, remand was required where record failed to support ALJ's assessment of claimant's ability to regularly stand for 6 hours or consistently lift up to 20 pounds.

Dist. Ct. erred in granting defendant-employee benefit plan's motion for summary judgment in ERISA action challenging defendant's denial of plaintiff's application for continued long-term disability benefits, where defendant based denial on plan's self-reported symptoms limitation. Defendant could not rely on said limitation where defendant had failed to include said limitation in summary plan description. However, Ct. rejected plaintiff's contention that Social Security Act prevented defendant from recouping prior overpayment of plan benefits resulting from plaintiff's receipt of social security benefits.

Dist. Ct. did not err in dismissing as untimely certain claims by plaintiffs-retirees alleging that defendant-pension plan miscalculated amounts owed to them where plaintiffs took early lump-sum distributions, and where defendant failed to include certain future interest credits when making said distributions. Dist. Ct. could properly conclude that applicable 6-year limitations period started at time plaintiffs received their lump-sum distributions, as opposed to prior time, when defendant initially circulated some information about calculation formula (as advocated by defendant) or at subsequent time, when plaintiffs became aware of applicable formula in full plan document (as advocated by plaintiffs). Ct. erred, though, in deferring to defendant when selecting means of calculating damages owed on timely claims.

Record contained sufficient evidence to support ALJ's denial of claimant's application for Social Security disability benefits, even though claimant alleged that she had sustained injuries to both of her arms, when ALJ ultimately determined that claimant could perform light work. ALJ could properly find that claimant was not credible when describing nature and extent of her disability where treating physician observed that his objective findings did not correlate with claimant's ongoing subjective complaints. Moreover, while ALJ improperly ignored opinion of state agency physician, any error was harmless where said physician did not personally treat claimant, and where opinion of treating physician supported ALJ's denial of benefits. Also, visual impairments suggested by medical record that included dry-eye syndrome were not of sort that would have significantly impacted claimant's ability to do light unskilled work.

Dist. Ct. did not abuse its discretion in denying plaintiff's petition for attorney fees under Equal Access to Justice Act after plaintiff became prevailing party in disability claim where plaintiff alleged that Social Security Commissioner's defense of ALJ's denial of said claim. Commissioner's defense of ALJ denial had rational basis in fact and law where ALJ merely miscalculated precise date as to when plaintiff became unable to do light duty work, and where record failed to show that ALJ ignored significant body of relevant evidence.

Record contained sufficient evidence to support Bd.’s denial of deceased claimant-coal miner’s claim for black lung benefits, as well as wife’s claim for black lung survivor’s benefits where ALJ found that weight of medical evidence indicated that claimant had died of cause other than pneumoconiosis. However, wife’s claim was entitled to reconsideration under 15-year presumption rule set forth in section 1556 of Black Lung Benefits Act that was enacted in 2010 since her claim had been filed after January 1, 2005 effective date for implementation of said rule. Ct. rejected employer’s argument that retroactive nature of section 1556 violated due process and takings clause of U.S. Constitution.

Dist. Ct. did not err in granting defendant-plan's motion for summary judgment in ERISA action challenging defendant's denial of plaintiff's application for disability benefits. Record showed that plaintiff failed to exhaust her administrative remedies by filing internal appeal of denial that was 11 days late. Moreover, plaintiff failed to show that 180-day period provided by defendant for filing internal appeal was too short of time period so as to deprive her of meaningful access to appeal procedures or that any administrative appeal would have been futile. Ct. also rejected defendant's argument that her untimely internal appeal should have been excused because she substantially complied with defendant's administrative review procedures.