Briggs v. National Fire Union Insurance Company of Pittsburgh, PA
1:16-cv-01197
W.D. Mich.Aug 8, 2017Background
- Decedent Christopher Neumann participated in an employer-sponsored AD&D plan administered under ERISA; coverage was funded by an insurance policy from National Union and described in a brief Benefits Guide given to employees.
- The National Union policy contained an exclusion for deaths arising from most air travel (except fare-paying passengers on scheduled/charter flights).
- Neumann and dependent Lloyd died in a 2014 plane crash; plaintiff Karen Briggs (personal representative and beneficiary) submitted AD&D claims to AIG (National Union’s claim administrator) and was denied.
- Briggs requested the plan’s SPD and plan documents from IPG/Interpublic Plan and National Union; IPG did not produce documents and AIG produced only the Benefits Guide (which disclaimed that it was not an SPD and referred to official plan documents).
- Briggs sued under ERISA for denial of benefits (§ 1132(a)(1)(B)), equitable reformation and breach of fiduciary duty (§ 1132(a)(3)), and civil penalties for failure to produce an SPD (§ 1132(c)(1)(B)).
- The district court considered motions to dismiss and resolved whether defendants could be proper parties and whether the Benefits Guide could support fiduciary-duty/estoppel claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper defendant for benefit claim under §1132(a)(1)(B) | The Interpublic Plan is a proper defendant because plans may be sued under §1132(d)(1) | IPG/Plan: only the plan administrator (or entity with claim authority) is the proper defendant | The Interpublic Plan may remain a defendant; IPG (employer) dismissed as to Count II (no authority to administer claims) |
| Whether Benefits Guide supports §1132(a)(3) breach-of-fiduciary/estoppel claims | Briggs: Benefits Guide omissions (no disclosure of air-travel exclusion) were material misrepresentations inducing reliance | Defendants: Benefits Guide disclaimed it was not an SPD; no reasonable employee would rely on it as the definitive plan terms | Dismissed Count III (reformation) and Count V (breach against IPG/Plan) for failure to plead material misrepresentation and reasonable reliance |
| National Union fiduciary-duty claim under §1132(a)(3) | Briggs: National Union failed to disclose its policy exclusions, inducing reliance on the Benefits Guide | National Union: same reliance and disclaimer arguments; no fiduciary duty-based misrepresentation shown | Dismissed Count IV against National Union for failure to state a §1132(a)(3) claim |
| Civil penalties for failure to produce SPD under §1132(c)(1)(B) | Briggs alleges IPG failed to produce an SPD after request | IPG failed to produce SPD; defendants raised procedural/merits defenses elsewhere | The opinion does not dismiss the §1132(c) claim in the court's disposition (other claims addressed); dismissal orders applied to specific counts as noted above |
Key Cases Cited
- Riverview Health Inst. LLC v. Med. Mut. of Ohio, 601 F.3d 505 (6th Cir. 2010) (proper defendant in ERISA benefit suits typically is the plan administrator)
- Daniel v. Eaton Corp., 839 F.2d 263 (6th Cir. 1988) (discussing proper defendants in ERISA benefit actions)
- James v. Pirelli Armstrong Tire Corp., 305 F.3d 439 (6th Cir. 2002) (elements for §1132(a)(3) fiduciary-misrepresentation claim: fiduciary status, material misrepresentation, detrimental reliance)
- Wilkins v. Baptist Healthcare Sys., Inc., 150 F.3d 609 (6th Cir. 1998) (availability of relief under §1132(a)(3) dependent on inadequacy of §1132(a)(1)(B) remedy)
- Gore v. El Paso Energy Corp., 477 F.3d 833 (6th Cir. 2007) (discussing ‘‘repackaging’’ defense and interaction of estoppel and statutory remedies)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: complaint must state a plausible claim)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must contain sufficient factual matter to be plausible)
- Blickenstaff v. R.R. Donnelley & Sons Co. Short Term Disability Plan, 378 F.3d 669 (7th Cir. 2004) (plans may be proper defendants in benefit suits)