Case Summaries

ERISA

[09/30] Golden Gate Rest. Ass'n v. City and County of San Francisco
In a challenge to municipally mandated employer health care spending requirements, summary judgment for plaintiff is reversed and the case remanded with instruction to enter summary judgment for defendant where the spending requirements are not preempted by ERISA because: 1) the spending requirements do not create an ERISA "plan" as defined by 29 U.S.C. section 1002(1); and 2) the spending requirements do not have an impermissible connection with employers' ERISA plans, or make impermissible reference to such plans.

[09/30] Simon v. Hartford Life, Inc.
In an ERISA case alleging breach of fiduciary duty by a plan administrator, motion to dismiss is affirmed where even a plan's sole beneficiary cannot, on behalf of an ERISA plan, bring a pro se action for breach of fiduciary duty under 29 U.S.C. section 1109(a).

[09/29] Vaught v. Scottsdale Healthcare Corp. Health Plan
In an ERISA challenge to denial of benefits, summary judgment for defendant is affirmed in part and reversed in part where: 1) issue preclusion does not apply in the ERISA context; 2) by notifying defendant of reasons why the claims administrator should reconsider the denial of claims, plaintiff invoked the plan's internal review procedures; and 3) by letting the initial determination stand, defendant made clear that internal review procedures were complete and thus plaintiff's administrative remedies were exhausted.

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