Rollins v. Dignity Health
19 F. Supp. 3d 909
N.D. Cal.2013Background
- Dignity Health is a nonprofit health system with facilities in multiple states; Rollins was employed as a billing coordinator at a Dignity hospital from 1986 to 2012; Rollins will be eligible for retirement benefits under Dignity’s Plan; Rollins alleges the Plan violates ERISA; Dignity argues the Plan is a church plan exempt from ERISA; Rollins seeks declaratory and injunctive relief and damages
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ERISA church-plan exemption requires establishment by a church | Rollins argues Section A requires establishment by a church | Dignity argues Section C allows church-associated maintenance to qualify | Church establishment required; Dignity not exempt |
| What constitutes “established and maintained” under 29 U.S.C. §1002(33) | Plain meaning supports establishment by church | Maintenance by church-associated organization suffices | Establishment by a church or convention of churches necessary; maintenance alone insufficient |
| Whether Section C expands church-plan eligibility beyond Section A | N/A | Section C broadens eligibility to church-associated organizations | No; Section A remains controlling; Section C is narrow |
| Whether the court should defer to IRS private letter rulings on ERISA church plans | N/A | IRS PLRs support Dignity's position | PLRs not binding; court does independent statutory interpretation |
| Whether Rollins' constitutional challenge or subject-matter jurisdiction arguments survive in light of ERISA posture | Constitutional challenge or jurisdiction may be viable if ERISA exemption applied | If not exempt, arguments moot; jurisdiction argued but rejected | Court declines purely constitutional or jurisdictional ruling pending ERISA merits |
Key Cases Cited
- BedRoc Ltd., LLC v. United States, 541 U.S. 176 (U.S. 2004) (preserves interpretive canons; give effect to every clause and word)
- In re Ariz. Appetito’s Stores, Inc., 893 F.2d 216 (9th Cir.1990) (statutory interpretation; plain meaning first)
- Russello v. United States, 464 U.S. 16 (U.S. 1983) (expressio unius est exclusio alterius doctrine aside for statutory construction)
- Bankers Life & Casualty Co. v. United States, 142 F.3d 973 (7th Cir.1998) (no deference to private letter rulings as precedent)
- Vasquez v. Los Angeles County, 487 F.3d 1246 (9th Cir.2007) (standard for reviewing motion to dismiss; favorable view of plaintiff's allegations)