Munro-Kienstra v. Carpenters' Health & Welfare Trust Fund
790 F.3d 799
8th Cir.2015Background
- Munro-Kienstra received treatment at the Mayo Clinic in Sept. 2008 and submitted a claim to the Carpenters' Health and Welfare Trust Fund; the plan denied coverage and the denial was final in July 2009.
- The plan is a self-funded multiple-employer welfare benefit plan maintained pursuant to collective bargaining agreements and is governed by ERISA.
- The plan expressly required any ERISA § 502(a) suit challenging denial of benefits to be filed within two years of the Trustees' final denial.
- Munro-Kienstra filed suit in federal court under ERISA § 502(a) in Jan. 2012, more than two years after the final denial.
- She argued the plan’s rules of construction incorporated Missouri law, which she said mandated a ten-year limitations period (Mo. Rev. Stat. § 516.110(1)) and barred shortening of limitations periods (Mo. Rev. Stat. § 431.030).
- The district court granted summary judgment for the plan as time-barred; the Eighth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the plan's two-year contractual limitations period governs Munro-Kienstra's ERISA claim | Plan's construction clause incorporates Missouri law; Missouri 10-year period controls, so two-year term is invalid | Parties adopted a contractual limitations period; under ERISA contractual periods apply unless unreasonable or preempted | The two-year contractual period governs; Munro-Kienstra's claim is time-barred |
| Whether plan's construction clause requires applying Missouri limitations law to override the plan's contractual period | The clause requires construing plan under Missouri law, so Missouri statutes (including § 431.030) apply | The construction clause is not a substantive incorporation of state law and does not displace ERISA; state law does not apply of its own force to ERISA suits | Construction clause does not import Missouri § 431.030 to invalidate the contractual period |
| Whether Mo. Rev. Stat. § 431.030 (prohibiting shortening of contract limitations) is a "controlling statute" that prevents the plan's limitations provision from taking effect | § 431.030 is controlling and prevents the two-year provision from taking effect | Applying § 431.030 would negate the plan provision and disrupt ERISA uniformity; ERISA preemption bars its application | § 431.030 is preempted as applied here and is not a controlling statute for Heimeshoff exception |
| Whether § 431.030 is saved from preemption as an insurance-regulating law or applies via the MEWA exception | § 431.030 regulates insurance and is saved from preemption; alternatively it applies to multiple-employer welfare arrangements | The plan is self-funded so the ERISA "deemer" clause prevents treating it as insurance; the MEWA definition excludes plans maintained pursuant to collective bargaining | § 431.030 is not saved as to this self-funded, collectively bargained plan; deemer clause and MEWA exclusion bar application |
Key Cases Cited
- Heimeshoff v. Hartford Life & Accident Ins. Co., 134 S. Ct. 604 (Sup. Ct.) (contractual ERISA limitations enforceable unless unreasonably short or a controlling statute prevents effect)
- Johnson v. State Mut. Life Assur. Co. of Am., 942 F.2d 1260 (8th Cir. 1991) (in absence of contractual period, borrow most analogous state statute)
- Doe v. Blue Cross & Blue Shield United of Wisconsin, 112 F.3d 869 (7th Cir. 1997) (enforce shortened contractual limitations in self-funded ERISA plans despite contrary state statute)
- Harris v. The Epoch Grp., L.C., 357 F.3d 822 (8th Cir. 2004) (parties may specifically incorporate state law for substantive plan terms, but not by broad governing-law clauses)
- Prudential Ins. Co. of Am. v. Nat'l Park Med. Ctr., Inc., 413 F.3d 897 (8th Cir. 2005) (discussing ERISA savings clause and the deemer exception for self-funded plans)