Posts Categorized: Court Cases

Anti-Assignment Provisions and Providers

in Court Cases, Health Benefits

Beginning last year, there has been a rash of court decisions giving ERISA participant and/or beneficiary status to providers based on assignments executed by participants at the point of service.  The most recent case was issued last week from the United States District Court for the Eastern District of Pennsylvania.  In the case, HOWARD BLOOM, D.C. and WEATHER VANE CHIROPRACTIC, P.C. v. INDEPENDENCE BLUE CROSS, the District Court once again granted ERISA participant status to the provider, based on an assignment executed by the participant at the point of service.  This is a dangerous trend as it grants to the… Continue Reading

State Income Tax Imputation for Same Sex Spouses

in Court Cases, Tax Issues

Since the Supreme Court allowed same sex marriage in all fifty states, employers have been busy turning off state income tax imputation for health benefits for those states that previously had not allowed same sex marriage. However, that only affects the period from and after June 26, 2015. Many employers have wondered what they should do with state income tax imputation that occurred January 1, 2015 through June 25, 2015. To date, only two states have issued definitive guidance on that issue – Michigan (Tax Notice, July 16, 2015) and Ohio (Notice EW 2015-01, July 2, 2015). For both Michigan… Continue Reading

Affect of Obergefell on Benefit Plans

in Court Cases, Health Benefits, Retirement Plans, Tax Issues, Welfare Benefits

For the second time in exactly two years, the United States Supreme Court has issued a landmark decision relating to same-sex marriages. Two years ago, in United States v. Windsor, the Court recognized same-sex marriages for federal law purposes. However, states were not required to recognize same-sex marriages entered into under the laws of another state. On June 26, 2015, in Obergefell v. Hodges, the Court went further, holding that all states must recognize a marriage as valid if it was valid in the jurisdiction in which it was performed, and also required that all states license same-sex marriages. State… Continue Reading

Supreme Court Upholds Contract Law for ERISA Plans

in Court Cases, Retiree Benefits

Today the Supreme Court upheld ordinary notions of contract law in interpreting ERISA plans, thereby apparently defeating the so-called “Yard-Man Inference.” In Yard-Man, the Sixth Circuit found a provision governing retiree insurance benefits ambiguous as to the duration of those benefits using two major theories.  First, the court inferred an intent to vest those benefits for life, under an illusory promise theory.  Second, the court relied on the context of labor negotiations to resolve ambiguities about vesting the benefits for life. The Supreme Court stated that the inferences applied in Yard-Man and its progeny do not represent ordinary principles of… Continue Reading

Supreme Court Upholds ERISA Limitation Periods

in Court Cases, Health Benefits, Retiree Benefits, Welfare Benefits

The U.S. Supreme Court in a unanimous decision has ruled that contractual limitations periods in ERISA plans are enforceable.  The only two qualifications that such limitation periods must satisfy is that they must be reasonable in length and not prohibited by another applicable statute.  In the instant case, the Supreme Court dealt with a disability plan that contained a 3-year limitations period.  The 3-year limitations period began on the day the person became disabled, not on the day that the final appeal was denied.  The court said that beginning the limitations period on the date of disability was appropriate.  ERISA’s… Continue Reading