Employee Benefits

Dist. Ct. erred in certifying two class actions alleging that defendants violated certain provisions of ERISA where, according to plaintiffs (beneficiaries of company 401(k) plans), defendants breached certain fiduciary duties owed to them by causing plans to pay excessive fees and expenses, including imprudent investment options in plans and concealing material information regarding plan fees and expenses. While instant causes of action have potential for class action treatment, and plaintiffs otherwise met commonality requirement of Rule 23(a)(2), plaintiffs failed to establish typicality requirement where many class members never held stock in particular stock funds at issue in complaint. Moreover, plaintiffs failed to demonstrate adequacy of representation requirement where scope of class members was too broad in that relief sought by named plaintiffs could have harmed other class members. However, on remand Dist. Ct. will be given opportunity to narrow scope of class.

Record failed to contain sufficient evidence to support ALJ denial of claimant's request for Social Security disability benefits arising out of various mental disorders, as well as arthritic bone and joint pain. ALJ failed to explain why she believed that claimant's testimony was incredible and ignored certain medical observations that supported claimant's assertions of joint and bone pain. ALJ also failed to ask vocational expert how many jobs claimant could perform with her combined disabilities. Ct., though, upheld denial of separate claimant's request for Social Security benefits where medical evidence supporting said claim pertained to claimant's condition at time after her social security disability coverage had expired.

Dist. Ct. did not err in remanding case back to agency for further proceedings where Dist. Ct. found that record did not support ALJ denial of claimant's application for Social Security disability benefits based on claimant's post-traumatic stress disorder. Remand to agency was appropriate based on finding that ALJ had not properly assessed credibility of witness and had failed to explain why opinion of treating physician had been discounted in favor of opinion from non-treating physician. However, claimant was not entitled to finding that would entitle him to disability benefits without remand where record contained potentially conflicting evidence that might support finding that claimant was not disabled during relevant time frame. Fact that case had been remanded back to agency at least twice did not entitle claimant to judicial award.

Dist. Ct. did not err in granting defendant's motion to dismiss plaintiff's ERISA claim alleging that defendant-purchaser of assets from plaintiff's bankrupt employer violated section 502 of ERISA when it failed to pay benefits pursuant to provisions contained in top hat pension plan (i.e., non-funded pension plan that was provided by bankrupt employer to senior executives in addition to standard pension plan provided to all of said employer's employees). Instant contract for sale of business assets did not include transfer to defendant of any liabilities arising under top hat plan, and plaintiffs failed to allege that defendant engaged in any conduct designed to deprive them of any plan benefits.

Record failed to support ALJ's denial of claimant's application for Social Security disability insurance benefits after ALJ discounted opinion of treating psychiatrist in weighing psychiatric medical evidence. Record suggested that claimant's mental impairments, which included depression and auditory and visual hallucinations, occurred over long period of time, and ALJ never explained why she would discount opinion of treating psychiatrist and rely instead on opinions of non-examining medical experts who demonstrated unfamiliarity with claimant's current condition.

Record failed to contain sufficient evidence to support ALJ denial of claimant's application for Social Security disability benefits based on certain mental impairments including schizophrenia and depression. ALJ failed to explain how she determined that claimant could perform last job as Wal-Mart clerk given claimant's mental impairments, and ALJ otherwise ignored symptoms of claimant's mental illness that could explain why he had difficulty taking his medications. Ct. further found that govt. could not rely on harmless error doctrine to avoid instant remand.

Dist. Ct. did not err in granting defendant-insurance company's motion for summary judgment in ERISA action alleging that defendant improperly denied plaintiff accidental death and dismemberment benefits arising out of initial injuries decedent received at work in September of 2005, where plaintiff died following complications from surgery to remove broken wire from plaintiff's knee in November of 2006. Applicable policy limited recovery to deaths occurring within one year of workplace accident, and removal of broken wire procedure was not separate accident where wire breakage was not unexpected complication arising out of original September 2005 surgery. Ct. further noted that policy did not provide benefits for injuries resulting from medical treatment.