Starla Rollins v. Dignity Health
830 F.3d 900
9th Cir.2016Background
- Starla Rollins sued Dignity Health alleging its pension Plan violates ERISA because it has not complied with ERISA’s requirements. Dignity Health concedes noncompliance but asserts the Plan is exempt as a “church plan.”
- The Plan originated from merged pension plans of Catholic hospital systems (Sisters of Mercy congregations / Catholic Healthcare West, later Dignity Health) and was declared a church plan by a CHW board resolution in 1992.
- Rollins became a Plan participant in 1999 after her hospital adopted the Plan; she challenges both the Plan’s church-plan status and the constitutionality of the church-plan exemption.
- ERISA defines a “church plan” as a plan “established and maintained” by a church (29 U.S.C. §1002(33)(A)), and subparagraph (C)(i) states that a plan established and maintained by a church “includes” plans maintained by certain church-controlled or affiliated principal-purpose organizations.
- The district court held that qualifying under §1002(33)(C)(i) still requires that the plan have been established by a church; it granted partial summary judgment for Rollins that the Plan must comply with ERISA and certified the question for interlocutory appeal.
- The Ninth Circuit affirmed: it read the statutory text and legislative history to require both establishment by a church and maintenance by either a church or an eligible principal-purpose organization, rejected IRS administrative interpretations and related-statute analogies, and rejected constitutional objections.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a “church plan” under ERISA §1002(33)(C)(i) must have been established by a church | Rollins: the statute requires a plan be both established and maintained by a church (or convention/association) to be a church plan | Dignity Health: subparagraph (C)(i) eliminates the establishment-by-church requirement when a principal-purpose org maintains the plan | Held: A church plan must still have been established by a church; (C)(i) only broadens who may maintain such a plan |
| Whether IRS and other statutes require a different ERISA interpretation | Rollins: IRS GCM and later statutes do not control ERISA’s separate definition and legislative history | Dignity Health: IRS opinions and later statutes show Congress intended maintenance alone by a principal-purpose org to suffice | Held: IRS GCM and later statutes are unpersuasive; ERISA’s text and history govern and require establishment by a church |
| Whether Chevron/agency deference compels accepting the IRS view | Rollins: the IRS GCM lacks force of law and misreads the statute; only Skidmore weight applies and it is unpersuasive | Dignity Health: IRS interpretation merits deference | Held: No Chevron deference; GCM gets only Skidmore deference and is unpersuasive |
| Constitutional challenges (Establishment/Free Exercise) to the court’s statutory reading | Rollins: statutory reading raises no constitutional infirmity | Dignity Health: distinguishing churches from other religious entities or examining church status raises Establishment/Free Exercise concerns | Held: No constitutional problem; statutory distinctions are based on objective organizational criteria and do not require inquiry into religious doctrine |
Key Cases Cited
- Nolan v. Heald Coll., 551 F.3d 1148 (9th Cir.) (summary judgment standard)
- Aetna Health Inc. v. Davila, 542 U.S. 200 (superseding purpose of ERISA to protect participants)
- Lockheed Corp. v. Spink, 517 U.S. 882 (ERISA protects employees’ relied-on benefits)
- Kaplan v. Saint Peter’s Healthcare Sys., 810 F.3d 175 (3d Cir.) (interpreting §1002(33)(C)(i) to require establishment by a church)
- Stapleton v. Advocate Health Care Network, 817 F.3d 517 (7th Cir.) (same interpretation)
- Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (agency deference framework)
- United States v. Mead Corp., 533 U.S. 218 (limits on Chevron deference)
- Green v. Bock Laundry Mach. Co., 490 U.S. 504 (burden when arguing legislative change of settled law)
- Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171 (ministerial exception and deference to church governance)