Rollins v. Dignity Health
59 F. Supp. 3d 965
N.D. Cal.2014Background
- Plaintiff Starla Rollins sued Dignity Health seeking a declaration that Dignity’s retirement plan (the "Plan") is not an ERISA-exempt "church plan" and injunctive relief to bring the Plan into ERISA compliance.
- Dignity argues the Plan is exempt because it was established by or jointly established with religious women’s orders (the "Sponsoring Congregations") that controlled Catholic Healthcare West (CHW), Dignity’s predecessor.
- CHW’s December 19, 1988 Board resolution states CHW approved and adopted the "Catholic Healthcare West Retirement Plan" effective January 1, 1989; later CHW documents and filings refer to CHW as the Plan’s establisher.
- Dignity contends (1) the Sponsoring Congregations were churches that established or effectively established the Plan via control of CHW, and (2) Rollins’s declaratory claim is barred or inequitable because of reliance on prior IRS rulings and statute-of-limitations arguments.
- The Court previously held that ERISA permits only a "church" to establish a church plan; mere church control or association is not enough. The question at summary judgment was whether genuine factual disputes preclude a declaration that CHW (not a church) established the Plan.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Plan is an ERISA "church plan" (i.e., "established by a church"). | Rollins: CHW established the Plan in 1989 and CHW is not a church, so the Plan is not exempt. | Dignity: Sponsoring Congregations (churches) controlled or jointly established the Plan, making it a church plan. | Held for Rollins — CHW (a separate corporation) established the Plan; no genuine fact issue that a church established it. |
| Whether the court should deny declaratory relief as not "appropriate equitable relief" under ERISA § 502(a)(3). | Rollins: Declaratory relief is equitable and appropriate to resolve statutory status. | Dignity: It would be inequitable to declare Plan non-exempt given prior IRS rulings that Dignity relied on. | Held for Rollins — declaratory relief is equitable; prior IRS rulings do not bar the remedy. |
| Whether Rollins’s declaratory claim is time-barred. | Rollins: ERISA § 413 (and analogous state statutes) do not apply to a declaratory action challenging church-plan status. | Dignity: § 413 or an analogous state statute bars the claim (six- or three-year periods). | Held for Rollins — ERISA § 413 applies to fiduciary-breach claims, not declaratory status claims; state analogues inapplicable. |
| Whether Sponsoring Congregations’ control of CHW imputes establishment of the Plan to them (veil piercing / joint establishment). | Rollins: CHW was a separate incorporated entity that resolved to establish the Plan; control allegations insufficient to impute establishment. | Dignity: Sponsoring Congregations’ control or merged plans show they established or co-established the Plan. | Held for Rollins — Dignity offered no legal basis or evidence to pierce CHW’s corporate veil or to show the Congregations exercised requisite control at Plan formation; merger/adoption documents post-date CHW’s establishment resolution. |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
- Celotex Corp. v. Catrett, 477 U.S. 317 (movant’s initial burden on summary judgment)
- Hodgers-Durgin v. de la Vina, 199 F.3d 1037 (declaratory relief is equitable)
- Guidry v. Sheet Metal Workers Nat. Pension Fund, 493 U.S. 365 (courts should not create equitable exceptions to statutory text)
- Dixon v. United States, 381 U.S. 68 (agency rulings contrary to statute are nullities)
- Harris Trust & Sav. Bank v. Salomon Smith Barney, 530 U.S. 238 (scope of ERISA remedies)
- Felton v. Unisource Corp., 940 F.2d 503 (on selecting analogous statutes of limitations)