Sanzone v. Mercy Health, No. 18-3574 (8th Cir. 2020)
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Plaintiff filed suit against Mercy Health, alleging that Mercy's plan management disregards requirements under the Employee Retirement Income Security Act. Mercy asserted that it does not have to comply with ERISA's requirements because the plan falls under ERISA's church-plan exemption pursuant to 29 U.S.C. 1003(b)(2).
The Eighth Circuit held that whether a plan is an ERISA plan is an element of the plaintiff's case and not a jurisdictional inquiry. Therefore, the district court erred in dismissing the case for lack of jurisdiction. The court remanded to the district court to determine whether the deprivation of ERISA protections confers Article III standing, and if so, whether the church-plan exemption violates the Establishment Clause. If there is Article III standing, the state law claims should be reinstated pursuant to the court's supplemental jurisdiction.
Court Description: [Smith, Author, with Wollman and Erickson, Circuit Judges] Civil case - ERISA. In action claiming the religiously affiliated hospital's ERISA plan was underfunded and violated the law in other respects, the plan fell within ERISA's exemption for retirement and pension plans of religiously affiliated nonprofits and plaintiff failed to adequately state a claim under ERISA; whether a plan is an ERISA plan is an element of a plaintiff's case and not a jurisdictional inquiry, and the district court erred in dismissing the case for lack of jurisdiction; with respect to plaintiff's claim that the exemption violates the Establishment Clause, the matter must be remanded to permit the district court to determine whether the deprivation of ERISA protections confers Article III standing, and if so, whether the church-plan exemption at issue here violates the Establishment Clause; if there is Article III standing, plaintiff's state law claims should be reinstated pursuant to the court's supplemental jurisdiction.
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