Jansen v. The Lincoln Financial Group
4:13-cv-04068
D.S.D.Nov 14, 2013Background
- Plaintiff Janelle Jansen was an employee of the Minute Clinic and a participant in its Group Long-Term Disability Plan, which is governed by ERISA.
- Jansen alleged the plan administrator/insurer wrongfully denied her long-term disability benefits and sued multiple defendants (Lincoln entities and the Minute Clinic Group of Employers).
- The original complaint asserted: an ERISA civil enforcement claim, a state-law contract claim, and a state-law tort (bad faith/punitive damages) claim.
- Defendants moved to dismiss under Rule 12(b)(6), arguing state-law contract and tort claims are preempted by ERISA and asking the court to require pleading under ERISA only.
- Jansen filed a proposed Amended Complaint that retained the tort claim; later she submitted a proposed Second Amended Complaint that removed the tort claim and pleaded only an ERISA claim for benefits.
- The court concluded the core dispute concerns denial of ERISA-governed benefits, granted leave to file the Second Amended Complaint, and denied the motion to dismiss as moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether state-law contract and tort claims relating to denial of benefits are preempted by ERISA | Jansen sought to recover benefits and originally asserted contract and tort claims (including bad faith and punitive damages); later amended to plead ERISA claim only | Defendants argued any state-law causes of action that concern plan benefits are preempted and amendment to include state-law claims is futile | Court held ERISA preempts state-law contract and tort claims that relate to administration/denial of plan benefits; Jansen may proceed only under ERISA and was granted leave to file the Second Amended Complaint |
| Whether leave to amend should be permitted | Jansen implicitly sought leave by filing proposed amended complaints and narrowed claims in the Second Amended Complaint to ERISA relief | Defendants opposed allowing an amended pleading that continued to allege state-law claims; did not oppose an ERISA-only amendment | Court granted leave to file the Second Amended Complaint (ERISA-only) and denied leave to file the earlier Amended Complaint that contained state-law claims |
Key Cases Cited
- Pilot Life Ins. Co. v. Dedeaux, 481 U.S. 41 (1987) (ERISA preempts state-law causes of action that relate to employee benefit plans)
- Cal. Div. of Labor Standards Enforcement v. Dillingham Constr., N.A. Inc., 519 U.S. 316 (1997) (ERISA preemption is broad and deliberate)
- Alessi v. Raybestos-Manhattan, Inc., 451 U.S. 504 (1981) (ERISA establishes federal primacy over pension plan regulation)
- Parkman v. Prudential Ins. Co. of Am., 439 F.3d 767 (8th Cir. 2006) (claims concerning administration of plan benefits fall within ERISA scope)
- Thompson v. Gencare Health Sys. Inc., 202 F.3d 1072 (8th Cir. 2000) (ERISA remedies preempt state common-law tort and contract actions about benefit claims)