Randolph v. East Baton Rouge Parish School System, No. 21-30022 (5th Cir. 2021)
Annotate this CaseThe Fifth Circuit reversed the district court's holding that the school system did not violate the Consolidated Omnibus Reconciliation Act of 1985 (COBRA) when it failed to provide plaintiff, a retired employee, notice of her right to continue her insurance coverage. The court explained that, while the placement on unpaid leave was a reduction of hours, it was not a qualifying event because it did not cause a loss of coverage. However, plaintiff's retirement caused a loss of coverage, and thus a qualifying event occurred, and the district court erred in concluding otherwise. The court further explained that a loss of coverage does not need to be contemporaneous to the qualifying event. Rather, the relevant question is whether a loss of coverage occurred within 18 months of a qualifying event. In this case, changes in the terms and conditions of plaintiff's coverage occurred within 18 months of her retirement. The court affirmed the district court's denial of plaintiff's request for payment of her medical expenses; remanded the district court's decision not to award statutory penalties or attorneys' fees to plaintiff; and vacated the district court's denial of plaintiff's motion to alter or amend judgment or for a new trial.
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