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Case Summaries

ERISA

[02/09] Arditi v. Lighthouse Int'l
In a lawsuit against an employer seeking retirement benefits, originally brought in state court and removed to federal court, the district court's denial of the plaintiff's motion to remand the case to state court and its dismissal of the action for failure to state a claim are affirmed, where: 1) removal to federal court was appropriate because the plaintiff's claims were preempted by ERISA; and 2) the district court properly dismissed the plaintiff's complaint because he failed to state a claim for relief that was plausible on its face.

[02/01] Muto v. CBS Corp.
In a putative class action complaint brought in New York by Pennsylvania residents against the plaintiffs' former employer and the employer's pension plan for benefits alleged to be due under ERISA, the district court's dismissal of the complaint as time-barred is affirmed, where: 1) the district court was correct in applying New York's borrowing statute directing it to look to Pennsylvania law for the applicable statute of limitations; and 2) plaintiffs' claims were untimely under Pennsylvania law.

[01/26] The DIRECTV Group, Inc. v. US
In a case involving the calculation and payment of segment closing adjustments associated with a corporation's sale of certain business units that included the transfer of defined benefit pension plans, the decision of the United States Court of Federal Claims granting summary judgment in favor of the corporation is affirmed, where: 1) the Claims Court did not err by calculating segment closing adjustments based on the assets and liabilities of the entire segment, rather than only the assets and liabilities that the corporation retained; and 2) the Claims Court correctly determined that the corporation's segment closing obligations could be satisfied by the cost savings realized by the government in the successor contracts.

[01/23] Leeson v. Transamerica Disability Income Plan
In an action under ERISA challenging the termination of the plaintiff's long-term disability benefits that was dismissed by the district court for lack of standing to pursue an ERISA claim and thus lack of federal subject matter jurisdiction, the dismissal is vacated and the case remanded, as the plaintiff's status as a participant for purposes of ERISA was a substantive element of his claim, not a prerequisite for subject matter jurisdiction.

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Workers' Comp

[02/09] Matter of Cappellino
On a claim for death benefits under the Workers' Compensation Law, the decision of the appellate division in favor of the defendant is reversed and the case remitted to that court to remand to the Workers' Compensation Board for further proceedings, where there was an undisputed finding that the employer untimely filed the notice of controversy and there was no showing of good cause or other reason to excuse the failure, so that the employer should have been precluded from offering its physician's testimony to dispute claimant's evidence on the issue of causation.

[01/11] Pacific Operators Offshore, LLP v. Valladolid
In an appeal from a judgment of the appeals court vacating an administrative dismissal of respondent's Outer Continental Shelf Lands Act (OCSLA) claim for benefits as a surviving spouse, judgment is affirmed where a claimant seeking benefits under the OCSLA must establish a substantial nexus between the injury and extractive operations on the shelf.

[12/13] In the Matter of Elrac, Inc. v. Exum
In an appeal from a judgment of the appellate division permitting arbitration of a claim by plaintiff-employee for uninsured motorist benefits, judgment is affirmed because a self-insured employer whose employee is involved in an automobile accident may be liable to that employee for uninsured motorist benefits, notwithstanding the exclusivity provision of the Workers' Compensation Law.

[10/31] County of Kern v. Workers' Comp. Appeals Bd
In an appeal from a judgment of the trial court affirming an administrative decision in a claim for worker's compensation, judgment is affirmed where a volunteer firefighter with a local nonprofit firefighting organization was a county employee for purposes of workers' compensation coverage under Labor Code section 3361.1.

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