Ibson v. United Healthcare Services, No. 16-3260 (8th Cir. 2017)
Annotate this CasePlaintiff filed suit against UHS under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132, seeking to recover unpaid benefits. The Eighth Circuit held that plaintiff could not bring claims for benefits due to her husband in her personal capacity, but rather, a legal representative of her husband's estate must bring the claim. Furthermore, plaintiff could not bring a section 1132(a)(3)(B) claim in equity. However, a restitutionary claim for premiums she paid under section 1132(a)(3)(B) was potentially available to her if there was a plan violation. The court remanded to the district court to determine initially if there was such a plan violation and, if so, whether restitution of plaintiff's premiums was "appropriate equitable relief" under section 1132(a)(3)(B). The court also held that the district court did not err in determining that UHS was not the plan administrator and plaintiff's breach of contract claim was preempted by ERISA.
Court Description: Shepherd, Author, with Wollman and Beam, Circuit Judges] Civil case - ERISA. For the court's prior opinion in the matter, see Ibson v. United Healthcare Servs., Inc.., 776 F.3d 941 (8th Cir. 2014). Whether plaintiff's claim to recover benefits related to her deceased husband's medical care are "unpaid benefits" under Section 1132(a)(1)(B) or extra-contractual damages forbidden under ERISA, the proper party to bring the claim is her late husband's estate; claim for the same benefits could not be maintained as an equitable claim; plaintiff could state an equitable claim for restitution of the premiums paid to defendant if there was a plan violation; remanded to the district court to determine initially if there was such a plan violation and, if so, whether restitution of the premiums is appropriate equitable relief under Sec. 1132(a)(3)(B); district court did not err in determining defendant was not the plan administrator for purposes of Sec. 1132(c)(1)(B); plaintiff's breach of contract claim was preempted by ERISA.
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