Niedermaier v. Southern Tier Building Trades Benefit Plan
Plaintiff Karl Niedermaier, a natural gas pipeline superintendent, sought health benefits coverage from the Southern Tier Building Trades Plan for his bilateral hearing loss and cochlear implant received in 2011. The Plan, through the Joint Board of Trustees, denied his requests for coverage, citing "artificial implant" and "hearing aid" exclusions. After two internal appeals were denied, Plaintiff commenced an action under ERISA to recover benefits. Both parties moved for summary judgment. The court found that while a cochlear implant is not a hearing aid, it reasonably falls under the "artificial implant" exclusion of the Plan. Therefore, the court granted the Defendants' motion for summary judgment and denied the Plaintiff's motion.