Baldwin v. University of Pittsburgh Medical Center
636 F.3d 69
| 3rd Cir. | 2011Background
- Baldwin, guardian/adoptive mother, sues UPMC and LINA to obtain ERISA benefits for Trent's biological children who were later adopted by Baldwin.
- Trent designated Baldwin as beneficiary of a $25,000 basic life policy; other policies had no named beneficiaries.
- After Trent's death, LINA denied benefits for the three policies other than the basic life policy, arguing the adopted children were no longer Trent's beneficiaries.
- ERISA claims focus on the meaning of the term “children” in the plans and on which party may have standing to sue for benefits.
- The district court held Baldwin lacked standing and limited interpretation to state-adoption law; this court holds Baldwin may introduce evidence on Trent’s intent to include the biological children and remand for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing under ERISA for the biological children | Baldwin has standing as guardian to seek benefits for the children | Adoption severed legal ties; children are not Trent's beneficiaries | Baldwin has statutory and prudential standing |
| Ambiguity of the term 'children' in the policies | Latent ambiguity allows extrinsic evidence on meaning | Term is unambiguous as biological vs. adopted status should define beneficiaries | Latent ambiguity exists; extrinsic evidence appropriate on remand |
| Contract interpretation under federal common law | Term for benefit eligibility should be interpreted to include biologic children if reasonably supported | Contract terms control; adoption effects must be respected | Interpretation guided by federal common law; extrinsic evidence considered on remand |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989) (establishes ERISA standing and remedial nature of statute)
- Leuthner v. Blue Cross & Blue Shield of NE Pa., 454 F.3d 120 (3d Cir. 2006) (defines colorable claim and zone-of-interest for ERISA standing)
- Miller v. Rite Aid Corp., 334 F.3d 335 (3d Cir. 2003) (zone-of-interests and standing in ERISA claims)
- New Valley Corp., 89 F.3d 143 (3d Cir. 1996) (applies common-law contract analysis in ERISA context; consider extrinsic evidence for ambiguity)
- Mellon Bank, N.A. v. Aetna Bus. Credit, Inc., 619 F.2d 1001 (3d Cir. 1980) (contract interpretation priority; words reflect intent; consider extrinsic evidence for latent ambiguity)
- Am. Eagle Outfitters v. Lyle & Scott Ltd., 584 F.3d 575 (3d Cir. 2009) (contract interpretation; unambiguous terms; objective manifestations of intent)
- Burstein v. Ret. Account Plan for Emps. of Allegheny Health Educ. & Research Found., 334 F.3d 365 (3d Cir. 2003) (ERISA contract interpretation under federal common law)