Central Valley Ag Cooperative v. Leonard, No. 19-3044 (8th Cir. 2021)Annotate this Case
Central Valley filed suit against various defendants who either marketed or administered self-funded health care plans, alleging that defendants breached various fiduciary duties and engaged in various prohibited transactions in violation of the Employee Retirement Income Security Act of 1974 (ERISA).
The Eighth Circuit affirmed the district court's grant of summary judgment for defendants. In regard to the 2015 health care plan, the court held that because Central Valley made the final payment decisions, AMPS and TBG did not have discretion over their compensation and were not fiduciaries. In regard to the 2016 health care plan, the court held that because none of Central Valley's allegations pertain to CDS's fiduciary duty of making benefit determinations on hospital and facility claims, Central Valley’s fiduciary duty claim against CDS fails. Furthermore, TBG, AMPS, and CDS did not act with discretion with respect to compensation, and thus no defendant became a fiduciary. Finally, the court rejected Central Valley's prohibited transactions claim. The court also affirmed the district court's award of attorney fees, holding that the district court properly balanced the Westerhaus factors and did not abuse its discretion in awarding defendants attorney's fees.