Legal Headlines

Case Summaries

ERISA

[09/30] Golden Gate Rest. Ass'n v. City and County of San Francisco
In a challenge to municipally mandated employer health care spending requirements, summary judgment for plaintiff is reversed and the case remanded with instruction to enter summary judgment for defendant where the spending requirements are not preempted by ERISA because: 1) the spending requirements do not create an ERISA "plan" as defined by 29 U.S.C. section 1002(1); and 2) the spending requirements do not have an impermissible connection with employers' ERISA plans, or make impermissible reference to such plans.

[09/30] Simon v. Hartford Life, Inc.
In an ERISA case alleging breach of fiduciary duty by a plan administrator, motion to dismiss is affirmed where even a plan's sole beneficiary cannot, on behalf of an ERISA plan, bring a pro se action for breach of fiduciary duty under 29 U.S.C. section 1109(a).

[09/29] Vaught v. Scottsdale Healthcare Corp. Health Plan
In an ERISA challenge to denial of benefits, summary judgment for defendant is affirmed in part and reversed in part where: 1) issue preclusion does not apply in the ERISA context; 2) by notifying defendant of reasons why the claims administrator should reconsider the denial of claims, plaintiff invoked the plan's internal review procedures; and 3) by letting the initial determination stand, defendant made clear that internal review procedures were complete and thus plaintiff's administrative remedies were exhausted.

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Labor & Employment Law

[10/10] Tate v. Executive Mgmt. Servs., Inc.
In a suit alleging sexual harassment and retaliation, jury verdict for plaintiff on his retaliation claim is reversed where plaintiff produced no evidence that he had engaged in protected activity by protesting his supervisor's alleged harassment.

[10/09] Lane v. Celadon Trucking, Inc.
In a case involving application of Indiana's lien reduction statute to defendant's worker's compensation subrogation lien on proceeds from a third-party settlement reached by plaintiff-former employee, decision to apply Indiana state law rather than Arkansas' made-whole doctrine is affirmed in part, reversed in part, and remanded where: 1) court did not believe the Arkansas Supreme Court would automatically apply the law of the state where the worker's compensation benefits were paid; 2) if faced with a choice-of-law question involving a dispute over worker's compensation subrogation rights, court predicted Arkansas Supreme Court would follow the district court's judgment in Simpson v. Liberty Mut. Ins. Co. in which defendant-worker's compensation carrier for employer was entitled to the proceeds in dispute; and 3) the lien reduction statute did not apply to defendant's lien and the district court erred in applying it.

[10/09] Kettenring v. Los Angeles Unified Sch. Dist.
In a class action lawsuit alleging that the compensation structure of defendant-school district violated state minimum wage laws, denial of plaintiff's writ of mandate challenging trial court decision that Labor Code's minimum wage provisions did not apply to defendant, is affirmed where: 1) adult education teachers fall within the professional exemption to Wage Order 4-2001; and 2) the salary structure did not violate Education Code section 45025, which requires proportional compensation for part-time employees.

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