Recent Supreme Court Cases Affecting Employee Benefit PlansBondBeebe
On our Payroll Auditing blog, Andrew Staab of Felhaber Larson Fenlon & Vogt recently provided a helpful overview of two Supreme Court decisions that affect employee benefit plans. These particular cases address when you need to act in order to preserve your rights. Here is a snapshot of the issues at hand:
Filing an Appeal
Ray Haluch Gravel Co. v. Central Pension Fund of International Union of Operating Engineers and Participating Employees, 134 U.S. 773 (2014) addresses the issue of when a fringe benefit fund must file an appeal to an adverse trial court decision. In the original case, the Fund was not awarded the full amount it requested in a collections lawsuit against the company, and after bringing a motion for attorney fees, it filed an appeal of the award of less than 100% of the claim for unpaid contributions.
The Supreme Court reviewed whether or not the Fund’s appeal of the court’s award was timely under the Federal Rules of Civil Appellate Procedure. They disagreed with the Fund and ruled that the Fund’s appeal was untimely because the appeal clock began ticking with the original award, not with the request for attorney fees.
The important take-away from this case is to properly track the appeals period without calculating a subsequent attorney fees motion. It’s interesting to note that fringe benefit funds will be able to use this argument to their benefit when delinquent employers want to appeal a decision while there is a pending attorney fee motion.
Statutes of Limitation
Heimeshoff v. Hartford Life & Accident Ins., 134 S.Ct. 604 (2013) deals with statutes of limitations within Summary Plan Descriptions. In this case, a plan participant brought a suit against the insurer regarding a denied claim after the limitations period specified in the plan.
The Supreme Court confirmed that parties to a contract, a Summary Plan Description, for example, can agree to a shorter statute of limitations period than what is put forth in state law. Even with the U.S. Department of Labor on her side, the court ruled against the participant. As Andrew states, going forward, there will likely be more cases around this issue.
For more details on both of these cases and how they may affect your plan, visit www.payrollauditing.com.