McKennan v. Meadowvale Dairy Employee Benefit Plan, No. 19-2163 (8th Cir. 2020)Annotate this Case
The Eighth Circuit reversed the district court's order requiring the Meadowvale Dairy Employee Benefit Plan to pay benefits and attorney's fees to Avera under the Employee Retirement Income Security Act of 1974 (ERISA). Avera alleged that the benefits at issue were due to a former employee of Meadowvale who received care at a hospital operated by Avera.
The court held that, although the beneficiary assigned any and all causes of action to Avera, he never had a cause of action against the Plan. Therefore, Avera may not proceed against the Plan under ERISA as an assignee of a beneficiary or otherwise. In this case, after Meadowvale rescinded the beneficiary's coverage under the Plan, neither the employee nor an authorized representative of his exhausted internal remedies to challenge the decision.