Justia U.S. 10th Circuit Court of Appeals Opinion Summaries

The Plaintiffs in this action were participants and beneficiaries of a life insurance plan offered by Defendant Qwest Communications International. In 2007, Plaintiffs filed a lawsuit against Qwest, arguing that the Plan made certain changes in violation of ERISA. The district court granted summary judgment in favor of Qwest. Plaintiffs raised seven issues on appeal to the Tenth Circuit, the sum of which was that the Plan misrepresented certain changes that unreasonably impacted employees' retirement benefits. Upon careful consideration of the arguments and applicable legal authority, the Tenth Circuit found that any misrepresentations were not material or in violation of ERISA. The Court affirmed the district court's grant of summary judgment in favor of the Plan.

The employee attempted to enroll in his employer's ERISA-regulated health care plan. The employer deducted premiums, but did not enroll the employee, who subsequently left the company and fell ill. The employee won $157,182 plus attorney fees under ERISA, then filed state law claims of fraud, misrepresentation, and breach of contract, which the employer removed to federal court. The district court denied remand and dismissed the claims as res judicata. The Tenth Circuit ordered remand to state court, holding that the state law claims are not completely preempted by ERISA and that the federal court did not have jurisdiction over those claims. While he was employed by the company, the employee would have had standing, under ERISA, to challenge the actions underlying the state claims; at the time he filed the suit, he did not have standing. Having already won an ERISA award, the employee no longer qualified as a former employee with a colorable ERISA claim.