insurance

Issues

Vermont enacted legislation that created a “unified health care database” designed to improve the affordability and quality of health care in Vermont by collecting and analyzing statewide data on insurance claims.  See Liberty Mut. Ins. Co. v. Donegan, 746 F.3d 497, 500–01 (2d Cir. 2014); see also Vt. Stat. Ann. tit. 18 § 9410(a)(1). Liberty Mutual offers a health insurance benefit plan to Vermont residents; the Employee Retirement Income Security Act of 1974 (“ERISA”) governs benefit plans. See id. ERISA requires benefits plans to make claim data reports to the Department of  Labor,  and generally preempts any state laws that relate to an employee benefit plan.  See id. at 503. In August 2011, the Vermont Department of Banking, Insurance, Securities and Health Care Administration (the “Department”) subpoenaed claims data from Blue Cross and Blue Shield of Massachusetts, the company that administers Liberty Mutual’s Plan. See id. at 502. In  district  court, Liberty Mutual sought to enjoin the subpoena, arguing ERISA preempted Vermont’s reporting requirements. See id. On appeal, the Court of Appeals for the Second Circuit held that ERISA did preempt the reporting requirements. See id. But Alfred Gobeille, chair of the Vermont Green Mountain Care Board, maintains that ERISA does not preempt Vermont’s law, because (1) Vermont’s law falls under the traditional state power to regulate health care, (2) the law does not infringe any core function of ERISA, and (3) Congress intended for states to retain the ability to collect health care data. See Brief for Petitioner, Alfred Gobeille at 25. Liberty Mutual counters, arguing that Vermont’s reporting requirements conflict with Congress’s intent to create a uniform federal reporting regime, and thus constitute precisely the kind of state law that Congress intended ERISA to preempt. See Brief for Respondent, Liberty Mut. Ins. Co. at 13. The Supreme Court’s resolution of this case will impact the cost to consumers of purchasing health care, the quality of that care, and the resources that the insurance companies must spend on claims data reporting procedures. See Brief of Amici Curiae AARP et al., in Support of Petitioner at 9-10, 11; Brief of Amici Curiae The American Benefits Council et al., in Support of Respondent at 24, 27-28.

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This case asks the Supreme Court to decide whether state public policy can impact the enforcement of a choice-of-law provision in a maritime contract. Great Lakes Insurance disputed an insurance claim for Raiders Retreat’s yacht and contends that under the choice-of-law provision in their contract, federal maritime law or, alternatively, New York law applied. Great Lakes argues that such provisions are presumptively enforceable under federal maritime law unless they are contrary to federal public policy. Raiders argues that state public policy can override the presumption of enforceability of choice-of-law provisions, and the state law or Restatement provisions followed by many states should apply. The outcome of this case bears important consequences on whether federal or state law should govern questions of maritime commerce, and whether courts should prioritize uniformity of law over state sovereignty.

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Petitioner, Bridget Hardt (“Hardt”), a former employee of Dan River Inc., brought suit against Respondent, Reliance Insurance Co. (“Reliance”), the insurance provider for Dan River Inc., in an attempt to recover attorney’s fees for a previous suit Hardt had brought in the Eastern District of Virginia to recover benefits pursuant to Dan River Inc.’s Group Long-Term Disability Insurance Program Plan (“the Plan”). The Eastern District remanded the case to Reliance, which, under ERISA, not only administers the Plan, but also decides whether an applicant is entitled to benefits. On remand, Reliance provided Hardt with the requested benefits. Hardt now sues seeking attorney’s fees under ERISA § 502(g)(1). Reliance counters that Hardt did succeed on the merits in the lower court and, therefore, cannot satisfy ERISA’s definition of “prevailing party.” Hardt, on the other hand, argues that the text of the statute does not include a prevailing party standard as a prerequisite to recovering attorney fees. In this case, the Supreme Court will decide whether ERISA § 502(g)(1) requires a party to succeed on the merits before attorney’s fees may be awarded and, if so, whether Hardt satisfies that requirement.

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In 2010, Congress passed the Patient Protection and Affordable Care Act (“ACA”). The ACA, in part, provides tax credits for insurance premiums to eligible citizens that obtain insurance through “Exchanges,” which are health insurance marketplaces. The IRS interpreted the ACA to permit tax credits to all eligible citizens regardless of whether the Exchange is federally or state-run. In this case, the Supreme Court will have the opportunity to resolve whether the ACA, which grants tax credits to individuals who obtained insurance through state-established Exchanges, also extends those tax credits to federally-established Exchanges. Several Virginia residents contend that the plain text of the ACA shows that Congress only intended for state-established Exchanges receive tax credits and that the Chevron deference is inapplicable because of the unambiguous meaning of the text. The government counters that tax credits are available to “applicable taxpayers”—a status determined independent of the type of Exchange within a citizen’s state—and, also, that the Chevron deference applies because the government’s interpretation avoids creating conflicts within the ACA. This case will profoundly impact the balance of federalism, the separation of power between the legislative and executive branches, and the American healthcare marketplace. 

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The Supreme Court will determine whether it is “appropriate equitable relief” under the Employee Retirement Income Security Act of 1974 (ERISA) to require a person to reimburse his benefits plan for medical expenses even though his settlement proceeds are dissipated. See Brief for Petitioner, Robert Montanile at i. ERISA governs the administration of private pension funds. ERISA section 502(a)(3) provides that “[a] civil action may be brought . . . by . . . [a] fiduciary . . . to obtain . . . appropriate equitable relief.” See 29 U.S.C. § 1132(a)(3). Robert Montanile received a $500,000 settlement in connection with injuries he sustained when he was in an accident with a drunk driver. Pursuant to an agreement, the Board of Trustees (the “Board”) of Montanile’s insurance plan sought to recover $120,044.02 from the settlement proceeds to reimburse the plan for covering Montanile’s medical expenses. When the parties were unable to settle, the Board sued Montanile under section 502(a)(3). But Montanile argues that reimbursement is not an appropriate equitable remedy here, because his settlement fund has been dissipated and an equitable lien by agreement can only be enforced against identifiable property and not Montanile’s general assets. See Brief for Petitioner at 29-32. The Board maintains that reimbursement is appropriate equitable relief, because the insurance plan has a reimbursement provision requiring Montanile to repay medical expenses. See Brief for Respondent, Board of Trustees of the National Elevator Industry Health Benefit Plan at 19. The Board contends that dissipation of the settlement fund does not nullify the insurance plan’s reimbursement provision. See id. The Court’s decision in this case could change benefit plans’ method of reimbursement and may cause beneficiaries to incur additional costs. See Brief of Amicus Curiae National Coordinating Committee for Multiemployer Plans, in Support of Respondent at 9-10, 12-15.

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This case asks the Supreme Court whether a former employee can sue over discrimination under the Americans with Disabilities Act after they have already left their job. Stanley argues that retirees, such as herself, have the right to sue regardless of whether they meet the definition of a qualified individual, and alternatively, that she qualifies as an eligible qualified individual even though she is suing post-employment. Sanford contends that Stanley did not previously argue that retirees have the right to sue regardless of their status as qualified individuals and has therefore waived her right to make this argument. Moreover, Sanford maintains that Stanley does not meet the definition of a qualified individual because Congress did not intend for employees to sue under the ADA post-employment. The outcome of this case has implications for disabled employees’ retirement benefits and the economic freedom of both employers and cities. 

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