Smith v. OSF Healthcare System, No. 18-3325 (7th Cir. 2019)Annotate this Case
In 1880, the Sisters, a Roman Catholic organization, founded OSF, which provides healthcare to indigent patients. The Sisters maintain authority through OSF’s governing documents and canonical and civil guidelines pertaining to church property. OSF merged with another Catholic hospital with the permission of the Holy See. Both offered employee pension plans before the merger. The Plans, with 19,285 participants, are now closed to new participants. Smith, a former employee and OSF plan participant, sued, claiming that the plans are not eligible for the church plan exemption under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 because they are administered by Committees that are not “principal-purpose organizations” and that the exemption itself is unconstitutional. She alleged that OSF allowed the plans to become severely underfunded; failed to follow notice, disclosure, and managerial requirements; and breached its fiduciary duties. The district court granted the defendants summary judgment despite plaintiff’s Federal Rule of Civil Procedure 56(d) motion to postpone the decision so that she could complete further discovery. The Seventh Circuit vacated. The summary judgment motion was filed long before discovery was to close; plaintiff was pursuing discovery in a diligent, sensible, and sequenced manner; and the pending discovery was material to summary judgment issues. The court’s explanation for denying a postponement overlooked earlier case-management and scheduling decisions and took an unduly narrow view of relevant facts.