Garan v. New York-Presbyterian Hospital
1:24-cv-06978
| S.D.N.Y. | Oct 4, 2024Background
- Plaintiff Jozef Garan filed suit against New York-Presbyterian Hospital in New York state court, claiming he was denied pension benefits owed under the hospital’s employee pension plan.
- Defendant New York-Presbyterian Hospital removed the case to federal court, arguing the plan is governed by ERISA, giving rise to federal jurisdiction.
- Garan, proceeding pro se, moved to remand the case back to state court.
- The pension plan at issue was maintained by the employer to provide retirement income, which meets ERISA's definition of an employee pension plan.
- The court considered whether removal to federal court was proper under the relevant provisions of ERISA and federal removal statutes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the hospital's pension plan is governed by ERISA | The plan should not trigger ERISA | The plan meets ERISA's definition | Plan is governed by ERISA |
| Whether federal court has jurisdiction under ERISA | Case should remain in state court | Federal court has jurisdiction per ERISA | Federal jurisdiction proper |
| Whether removal to federal court was proper | Removal was not procedurally valid | Removal was appropriately effected | Removal was proper |
| Whether case should be remanded to state court | Move to remand to state court | Oppose remand; keep in federal court | Remand motion denied |
Key Cases Cited
- Triestman v. Fed. Bureau of Prisons, 470 F.3d 471 (2d Cir. 2006) (courts must liberally construe pro se pleadings)
- Yurcik v. Sheet Metal Workers’ Int’l Ass’n, 889 F. Supp. 706 (S.D.N.Y. 1995) (ERISA benefits claims removable to federal court)
- Johnson v. First Unum Life Ins. Co., 914 F. Supp. 51 (S.D.N.Y. 1996) (concurrent federal and state court jurisdiction under ERISA)