W.A. Griffin v. Coca-Cola Enterprises, Inc.
686 F. App'x 820
| 11th Cir. | 2017Background
- Pro se plaintiff Dr. W.A. Griffin sued Coca-Cola Enterprises (CCE) under ERISA § 502(a) seeking payment for services rendered to plan member A.H., alleging Blue Cross Blue Shield (BCBS), claims administrator, failed to pay full amounts.
- Griffin alleged she held written assignments of benefits from A.H. but the plan contained an unambiguous anti-assignment clause forbidding member assignment without BCBS written permission.
- The district court dismissed Griffin’s amended complaint for failure to state an ERISA claim, finding she lacked statutory (derivative) standing because the assignments were void under the anti-assignment provision.
- Griffin argued CCE waived the anti-assignment defense (or should be estopped from invoking it) and that Georgia law (O.C.G.A. § 33-24-54) precluded enforcement of anti-assignment clauses.
- The Eleventh Circuit reviewed de novo and affirmed: the plan’s anti-assignment language was clear and enforceable, Georgia statute did not nullify the clause, and Griffin alleged no facts showing waiver or estoppel by CCE.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Griffin has ERISA standing via written assignments | Griffin asserted she had valid written assignments from member A.H. giving her derivative standing to sue under ERISA | CCE relied on plan’s unambiguous anti-assignment clause voiding the assignments | Held: No standing; anti-assignment clause unambiguous and enforceable, assignments voided |
| Whether Georgia statute (O.C.G.A. § 33-24-54) invalidates anti-assignment clauses | Griffin argued state law renders anti-assignment provisions unenforceable and thus preserves her assignments | CCE argued ERISA preempts state law and statute does not explicitly prohibit anti-assignment clauses for ERISA plans | Held: Georgia statute does not explicitly prohibit anti-assignment clauses; clause remains enforceable; ERISA preemption principles control |
| Whether CCE waived or is estopped from asserting the anti-assignment clause | Griffin contended CCE’s conduct (e.g., prior communications) waived its right to enforce the clause or should be estopped | CCE denied waiver; pointed to lack of facts showing clear relinquishment or misleading conduct | Held: No waiver or estoppel; plaintiff pleaded only a limited one-way contact and failed to allege facts showing express or implied waiver |
| Whether to certify a question to a supreme court | Griffin sought certification to a Supreme Court (unclear which) to resolve law | CCE opposed (implicitly), arguing no extraordinary question presented | Held: Motion denied for lack of identified question of national or unresolved state law importance |
Key Cases Cited
- Behrens v. Regier, 422 F.3d 1255 (11th Cir.) (12(b)(6) standard and de novo review)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleading)
- Physicians Multispecialty Grp. v. Health Care Plan of Horton Homes, Inc., 371 F.3d 1291 (11th Cir.) (unambiguous anti-assignment clauses in ERISA welfare plans are enforceable)
- America’s Health Ins. Plans v. Hudgens, 742 F.3d 1319 (11th Cir.) (ERISA preemption and treatment of self-funded plans under state insurance law)
- In re Garfinkle, 672 F.2d 1340 (11th Cir.) (elements of waiver and estoppel under federal common law)
- Witt v. Metro Life Ins. Co., 772 F.3d 1269 (11th Cir.) (noting open question whether waiver applies under ERISA federal common law)
- Polston v. Boomershine Pontiac-GMC Truck, Inc., 952 F.2d 1304 (11th Cir.) (standards for certifying questions to state supreme courts)