418 F. App'x 498
7th Cir.2011Background
- Huss, a former IBM employee, sought to enroll her dependent adult son Joseph in the IBM Medical and Dental Plan under ERISA.
- The Plan’s administrator Barnes denied enrollment based on the 2006 Summary Plan Description (SPD).
- Huss argued the 2003 SPD controlled because the critical action occurred before 2004, and thus a pre-2004 rule applied.
- District court granted Huss summary judgment for immediate enrollment and awarded statutory penalties and fees.
- We held Barnes erred by relying on the 2006 SPD; the 2003 SPD controlled for the conditional eligibility and remanded for further proceedings.
- We also held some penalties improper and vacated the attorney’s-fees award, remanding for redetermination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which SPD governs eligibility at the time of denial | Huss: 2003 SPD controls; actions before 2004. | IBM: 2006 SPD controls; denial based on written-continuation requirement. | Remand to apply 2003 SPD; not fully grant enrollment. |
| Whether Huss’s pre-2004 actions satisfied any continuance requirement | Huss acted timely; calls before 2004 should count. | Contemporaneous written-application requirement applied. | Issues of fact; remand for complete administrative review. |
| Allowance of statutory penalties for document disclosure | Penalties justified for delayed production of controlling documents. | Penalties improper for certain post-2004 documents. | First penalty upheld; second penalty vacated. |
| Award of attorney’s fees | Hardt allows fees for some success on the merits. | Fees inappropriate if position substantially justified. | Fees vacated; remanded to district court for reconsideration. |
Key Cases Cited
- Hackett v. Xerox Corp. Long-Term Disability Income Plan, 315 F.3d 771 (7th Cir. 2003) (controlling plan language must apply at denial when unambiguous)
- Dabertin v. HCR Manor Care, Inc., 373 F.3d 822 (7th Cir. 2004) (administrative discretion; plan terms govern interpretation)
- Swaback v. American Info. Techs. Corp., 103 F.3d 535 (7th Cir. 1996) (deference to administrator; avoid arbitrary decisions)
- Speciale v. Blue Cross & Blue Shield Ass’n, 538 F.3d 615 (7th Cir. 2008) (need for reasonable interpretation of plan documents)
- Mondry v. Am. Family Mut. Ins. Co., 557 F.3d 781 (7th Cir. 2009) (disclosure scope under 1024(b)(4) is narrow; not all relevant docs)