Posts Categorized: Retiree Benefits

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

Clear Win for ERISA Health Plans

in Court Cases, Health Benefits, Retiree Benefits

Early this week the United States Supreme Court issued an important decision for health plans seeking to enforce their rights to reimbursement with respect to third party recoveries. The case, US Airways v. McCutchen, 569 U.S. ___ (2013), deals with the common situation where a health plan participant receives a settlement on account of a third party injury and the plan seeks reimbursement of the medical expenses it paid on the participant’s behalf with respect to the injury. In a clear win for plan sponsors, the Supreme Court held unanimously that an express provision in the plan document authorizing the… Continue Reading