SKORUPSKI v. LOCAL 464A UNITED FOOD AND COMMERCIAL WORKERS WELFARE SERVICE BENEFIT FUND, 2:22-cv-03804-SDW-JBC

Plaintiff Robert Skorupski is a participant in an ERISA-governed welfare plan; his wife Stacy is a beneficiary who incurred medical treatment for pancreatitis and pancreatic duct disruption in 2020.
Plaintiffs incurred roughly $581,381 in medical bills after repeated hospitalizations; some treating records noted alcohol-related pancreatitis and Stacy admitted to nightly vodka consumption before symptoms.
The Plan expressly excludes coverage for conditions “provided in connection with or in treatment for alcoholism, alcohol abuse, and/or alcohol use or misuse” and related conditions; the Board interprets that exclusion to bar coverage when alcohol use is a contributing cause.
The Welfare Fund denied benefits under that exclusion; the Board upheld the denial on appeal; Plaintiffs sued under ERISA §§ 502(a)(1)(B) and (a)(3).
The court converted defendants’ Rule 12(b)(6) motion to a Rule 56 summary-judgment motion, applied the arbitrary-and-capricious standard (because the Plan grants the Board discretionary authority), and granted summary judgment for defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard of review for administrative denial	Evidence disputes require de novo review	Plan gives Board discretionary authority → deferential arbitrary-and-capricious review	Arbitrary-and-capricious standard applies because Plan grants discretion
Whether benefit denial was arbitrary and capricious	Medical letters and research create a genuine dispute about causation	Medical records and beneficiary admissions show alcohol contributed; Board’s interpretation is reasonable	Denial supported by substantial evidence; not arbitrary or capricious; summary judgment for defendants
Availability of relief under ERISA § 502(a)(3) for past monetary benefits	Seeks declaratory judgment that bills are covered and payment obligated	§ 502(a)(3) is limited to equitable relief and cannot impose personal liability for past monetary obligations	§ 502(a)(3) does not permit compelling payment of past benefits; claim fails
Breach of fiduciary duty under § 502(a)(3)	Alleged breach by denying payment of bills	Claim is indistinguishable from a benefits claim and seeks monetary relief, not equitable remedies	Dismissed: plaintiff failed to identify specific fiduciary breaches and sought improper monetary relief

Fleisher v. Standard Ins. Co., 679 F.3d 116 (3d Cir. 2012) (arbitrary-and-capricious review applies where plan grants administrator discretionary authority)
Varity Corp. v. Howe, 516 U.S. 489 (1996) (§ 502(a)(3) is a catchall providing equitable relief to redress ERISA violations)
Great-West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204 (2002) (§ 502(a)(3) does not authorize equitable relief that is, in substance, a request to compel payment of a past monetary obligation)
Mertens v. Hewitt Associates, 508 U.S. 248 (1993) (scope of "appropriate equitable relief" under § 502(a)(3) is limited to remedies traditionally available in equity)
Bergamatto v. Bd. of Trs. of the NYSA-ILA Pension Fund, 933 F.3d 257 (3d Cir. 2019) (administrator interpretations reasonable if consistent with plan text)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment and genuine dispute/matters for trial standard)