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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

In Re J.P. Morgan Chase Cash Balance Litigation

Plaintiffs alleged that the JPMorgan Chase Retirement Plan implemented by JPMorgan Chase violated ERISA by being age discriminatory and by failing to provide adequate notice of reduced benefit accruals after converting to a cash balance plan. Defendants moved to dismiss all remaining counts. The court denied the motion to dismiss for the age discrimination claim (Count I) and the notice claims (Counts IV-VI), interpreting ERISA's "rate of benefit accrual" to refer to the employee's retirement benefit, which is detrimentally affected for older workers in cash balance plans. The court found that the plan conversion could lead to a significant reduction in benefit accrual, requiring notice. Counts II and III, related to back-loading and forfeiture claims, were dismissed as they had been withdrawn by the plaintiffs.

ERISAAge DiscriminationCash Balance PlansDefined Benefit PlansDefined Contribution PlansBenefit AccrualStatute of LimitationsMotion to DismissNotice RequirementsSummary Plan Description
References
23
Case No. 04-15-00469-CV
Regular Panel Decision
Jul 09, 2015

Cash Biz, LP, Redwood Financial, LLC, Cash Zone, LLC Dba Cash Biz v. Hiawatha Henry, Addie Harris, Montray Norris, and Roosevelt Coleman Jr.

This case involves an interlocutory appeal by Cash Biz, LP and its affiliates against Hiawatha Henry and other appellees. Cash Biz is challenging a trial court's order denying its motion to compel arbitration and enforce a class action waiver. The appellees had sued Cash Biz for malicious prosecution, fraud, and statutory violations after Cash Biz filed criminal charges against them related to defaulted loan contracts. The trial court ruled that Cash Biz's actions in using the criminal justice system to collect a civil debt constituted a waiver of its right to arbitrate and that the arbitration clauses were inapplicable. Cash Biz argues that the appellees' claims fall within the broad scope of their arbitration agreements and that merely filing criminal complaints does not legally constitute a 'substantial invocation of the judicial process' to waive arbitration.

ArbitrationClass Action WaiverMalicious ProsecutionFraudDebt CollectionLoan ContractsTexas Arbitration ActFederal Arbitration ActWaiver of ArbitrationInterlocutory Appeal
References
0
Case No. 01-cv-7920 (AKH)
Regular Panel Decision
Aug 29, 2006

Hirt v. Equitable Retirement Plan for Employees

This Second Supplementary Decision and Order for Judgment addresses three key issues: the effective date of Equitable's cash balance plan, the applicable statute of limitations, and the implementation of prior rulings. The court established January 18, 1993, as the effective date for the cash balance plan. Crucially, it ruled that the named plaintiffs' class action, filed on August 23, 2001, was time-barred under New York's six-year statute of limitations, as their cause of action accrued on January 18, 1993. However, the decision clarified that class members not directly party to this lawsuit are not bound by this limitation and retain their right to pursue claims. Finally, the plaintiffs' request for an ombudsman role in judgment implementation was denied.

ERISACash Balance PlanStatute of LimitationsClass ActionEmployee BenefitsPension PlanNotice RequirementsDe-grandfatheringFederal Discovery RuleRepudiation
References
13
Case No. 15-24-00114-CV
Regular Panel Decision
Oct 04, 2024

Cecile Erwin Young, in Her Official Capacity as the Executive Commissioner of the Texas Health and Human Services Commission; Molina Healthcare of Texas, Inc.; And Aetna Better Health of Texas, Inc. v. Cook Children's Health Plan, Texas Children's Health Plan, Superior Health Plan, Inc., and Wellpoint Insurance Company

This case involves an appeal concerning a temporary injunction and the denial of a plea to the jurisdiction issued by the 353rd Judicial District of Travis County. The appellants, including Cecile Erwin Young (Executive Commissioner of HHSC), Molina Healthcare of Texas, Inc., and Aetna Better Health of Texas, Inc., are challenging the lower court's decision. The appellees (Cook Children's Health Plan, Texas Children's Health Plan, Superior Health Plan, Inc., and Wellpoint Insurance Company) had sought to enjoin the Texas Health and Human Services Commission (HHSC) from proceeding with STAR & CHIP and STAR Kids managed care procurements. The core legal arguments revolve around whether HHSC's procurement processes violated Texas law, thereby rendering the intended contract awards unlawful ultra vires acts, and whether the appellees' claims are barred by sovereign immunity or failure to exhaust administrative remedies. The appellants contend that the district court abused its discretion by granting the injunction and denying the plea.

Appellate CourtTemporary InjunctionPlea to the JurisdictionSovereign ImmunityUltra Vires ClaimsProcurement DisputeManaged Care ContractsMedicaidCHIPTexas Health and Human Services Commission
References
95
Case No. 03-04-00560-CV
Regular Panel Decision
Jul 27, 2005

Gwen Cash v. Keith Lovell Cash

This case involves an appeal by Gwen Cash against a final divorce decree. She argued that the written order incorrectly varied from a prior oral ruling concerning the division of her former husband's disability benefits, community tax obligations, and any undisclosed property. Mrs. Cash requested that the written order be reformed to align with the more favorable oral pronouncement. The Court of Appeals affirmed the judgment, concluding that the trial court had plenary power to modify its judgment and did not abuse its discretion in the property division, especially since the written decree was a result of subsequent negotiations between the parties.

Divorce DecreeProperty DivisionOral RulingWritten OrderPlenary PowerAbuse of DiscretionAppellate ReviewCommunity PropertyDisability BenefitsTax Obligations
References
8
Case No. MISSING
Regular Panel Decision

Humphrey v. United Way of Texas Gulf Coast

This ERISA case involves cross-motions for summary judgment regarding the calculation of early retirement pension (ERP) benefits under a cash balance plan. Plaintiff Ann W. Humphrey, beneficiary of Fredrick B. Blackmer, disputes the "greater of" methodology used by United Way of the Texas Gulf Coast Cash Balance Plan, advocating for the "plus" methodology detailed in earlier plan documents. The court grants the Plaintiff's motion, finding the plan administrator abused its discretion by using an interpretation that directly conflicts with the plain language of the 96 Plan, particularly Section 6.5. The court rejects the defendant's arguments regarding the Summary Plan Description's control, the lack of abuse of discretion, and the "scrivener's error" defense. The final order declares that ERP benefits must be calculated by adding the benefits from the Prior Plan and the 96 Plan and orders defendants to recompute benefits accordingly.

ERISAPension BenefitsEarly Retirement PensionCash Balance PlanDefined Benefit PlanSummary JudgmentAbuse of DiscretionPlan InterpretationScrivener's ErrorClass Action
References
38
Case No. MISSING
Regular Panel Decision

In re Robert Plan Corp.

Kenneth Kirschenbaum, the Chapter 7 Trustee for The Robert Plan Corporation and The Robert Plan of New York Corporation, sought court approval for fee awards for himself and his professionals for administering an ERISA plan. The U.S. Department of Labor (DOL) objected, asserting the court lacked jurisdiction to award fees from Plan assets and had specific objections to the reasonableness of the fees. The court affirmed its core jurisdiction over the Trustee's actions as Plan administrator and his professionals' compensation, regardless of whether payments came from Plan or estate assets, citing previous rulings. The court analyzed whether Bankruptcy Code §§ 326 and 330 conflicted with ERISA statutes concerning fiduciary compensation, concluding no substantive conflict existed and the Bankruptcy Code's specific compensation scheme governed. Ultimately, the court largely overruled DOL's objections and granted the fee applications for the Trustee, K & K, Witz, and Whitfield, deeming the requested amounts reasonable and compliant with the Bankruptcy Code. The awards are payable from the Plan's Pguy Account, with any shortfall covered by the Debtors' estate.

Bankruptcy LawERISAChapter 7 TrusteeFee ApplicationPlan AdministrationJurisdictionReasonable CompensationStatutory ConstructionDepartment of LaborFiduciary Duties
References
50
Case No. 07-09-00163-CV
Regular Panel Decision
Mar 12, 2010

Potter County, Texas as Plan Administrator for the Health Benefits Plan for the Employees of Potter County, Texas v. Ronda Tuckness and Michael Tuckness

Potter County, acting as the plan administrator for its employee health benefits plan, appealed an order that denied its plea to the jurisdiction. The underlying lawsuit was filed by Ronda and Michael Tuckness, seeking health care benefits after the County denied Michael Tuckness's claim for back surgery costs due to an occupational injury exclusion. The County contended it was immune from suit. The appellate court found that the County's governmental immunity had not been waived by the requests for declaratory relief, the terms of the health plan contract, or the County's conduct. Consequently, the court reversed the trial court's order and dismissed the Tucknesses' case for lack of subject-matter jurisdiction.

Governmental ImmunityImmunity WaiverDeclaratory JudgmentContract LawHealth BenefitsPlan AdministratorOccupational Sickness/InjuryJurisdictionPlea to JurisdictionInterlocutory Appeal
References
20
Case No. MISSING
Regular Panel Decision

Pig Newton, Inc. v. Boards of Directors of the Motion Picture Industry Pension Plan

Plaintiff Pig Newton, Inc. commenced an action against the Boards of Directors of the Motion Picture Industry Pension Plan, Health Plan, and Individual Account Plan, seeking a declaration that certain provisions of the Plans’ Trust Agreements were invalid and unenforceable. The Defendants counterclaimed for delinquent contributions under ERISA. The core dispute revolved around "Controlling Employee Provisions" in the Trust Agreements, which obligated employers to contribute for Controlling Employees for a specified number of hours and weeks regardless of actual hours worked. Pig Newton argued these provisions were invalid, not properly incorporated, or conflicted with collective bargaining agreements (CBAs). The Court, applying federal common law and an arbitrary and capricious standard of review for the Directors' interpretation, found the provisions valid, properly incorporated, and not in conflict with the CBAs, concluding that Szekely (Pig Newton's sole owner) qualified as a Controlling Employee. Consequently, the Court denied Plaintiff's motion for summary judgment and granted Defendants' cross-motion for summary judgment, dismissing Plaintiff's complaint and awarding Defendants the sought-after contributions, interest, auditors’ fees, and liquidated damages.

ERISAMultiemployer PlanPension PlanHealth PlanDeclaratory JudgmentSummary JudgmentTrust AgreementsCollective Bargaining AgreementsControlling Employee ProvisionsDelinquent Contributions
References
44
Case No. MISSING
Regular Panel Decision

Rosenblatt v. United Way of Greater Houston

Stanley Rosenblatt, a long-time employee of the Jewish Community Center, participated in United Way of Greater Houston's defined benefit pension plan. In 1995, United Way converted this to a cash balance plan (CB Plan) due to a significant funding deficit, later adding a "wear-away" provision and freezing accruals. Rosenblatt alleged age discrimination with the EEOC, claiming the CB Plan adversely affected older employees by reducing benefit accruals and miscalculating benefits. United Way filed motions to dismiss, arguing that Rosenblatt failed to state a claim under ERISA and ADEA, citing circuit court precedents upholding cash balance plans as non-discriminatory. The Court sided with United Way, concluding that Rosenblatt's claims regarding benefit accruals, notice requirements, minimum participation standards, and breach of fiduciary duty lacked sufficient factual basis under ERISA and ADEA. Consequently, the defendants' motions to dismiss were granted, and the case was dismissed.

Age DiscriminationERISAADEACash Balance PlanDefined Benefit PlanPension PlanMotion to DismissBenefit AccrualFiduciary DutyStatutory Interpretation
References
26
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