The case concerns a former employee's lawsuit against Hartford Life and Accident Insurance Company under ERISA, 29 U.S.C. § 1132(a)(1)(B), seeking recovery of long-term disability benefits under an employer-sponsored group plan after the insurer terminated payments in 2006 despite the plaintiff's claimed disabilities including lupus and fibromyalgia. The defendant filed a motion to dismiss any improper ERISA claims, particularly challenging the request for disgorgement of profits as potentially exceeding the remedies available under the statute. The court reviewed the complaint, the plan documents, and relevant Eleventh Circuit precedent on proper defendants and available causes of action, noting that the plaintiff had pleaded only the benefits claim and had not asserted a separate equitable claim under § 1132(a)(3). The core reasoning focused on ERISA's limited statutory remedies and whether the facts alleged supported a contract-based action to recover benefits or enforce plan rights.
In Haddad v. Dudek, a quadriplegic plaintiff sued Florida state agencies under the Americans with Disabilities Act and Rehabilitation Act, seeking an order to provide her with home and community-based services through the Traumatic Brain Injury/Spinal Cord Injury Medicaid waiver program rather than requiring placement in a nursing facility. The defendants moved to dismiss the complaint for failure to state a claim. The court denied the motion, holding that the complaint sufficiently alleged facts showing the plaintiff was a qualified individual with a disability who was being denied services in the most integrated setting appropriate to her needs. The decision relied on the integration mandate recognized in Olmstead v. L.C. and found the allegations plausible on their face without reaching the merits of any fundamental alteration defense.
This case involves a plaintiff's claim under the Employee Retirement Income Security Act (ERISA) that her employer's disability insurer improperly denied her benefits. The court addressed multiple procedural motions, including the plaintiff's request to delay consideration of the defendant's summary judgment motion pending discovery, objections to a magistrate judge's discovery order, and requests to extend case deadlines. The court granted an extension of pretrial and trial deadlines to allow for discovery regarding the defendant's conflict of interest, overruled the defendant's objections to the magistrate's order requiring production of the administrative record, and denied the summary judgment motion without prejudice to refiling after a reasonable discovery period. The reasoning centered on the need for meaningful discovery before dispositive motions in ERISA cases where the administrative record and potential conflicts must be examined.
The case involved a plaintiff suing Citicorp Trust Bank over its management of trust assets, with claims including violation of the Florida Securities and Investor Protection Act (FSIPA), breach of fiduciary duty, negligence, negligent misrepresentation, and fraud. After partial summary judgment for the defendant and a jury verdict in its favor on the remaining claim, the defendant sought attorneys' fees under Florida Statutes section 517.211(6) for defending the FSIPA claim and related fraud claims. The court applied Florida law and found fees recoverable for the FSIPA claim and sufficiently intertwined claims, but reduced the requested amount substantially after determining that billing records reflected excessive hours, unnecessary double-billing by multiple attorneys, and work unrelated to the fee-eligible claims.
The case involved Patricia Epolito's dispute with Prudential over long-term disability benefits under an ERISA plan tied to her employment at Kemper Auto & Home, which was later acquired by Unitrin. After initially receiving LTD benefits, Epolito also began collecting pension benefits from the Kemper plan and retroactive social security disability benefits, prompting Prudential to terminate LTD payments and seek offsets plus recovery of alleged overpayments. The court considered cross-motions for summary judgment on whether the plan permitted offsets for pension benefits and whether Prudential could impose an equitable lien to recoup overpayments from the retroactive SSD award. The court held that Prudential's offset for pension benefits was a reasonable plan interpretation, but Prudential failed to establish an equitable lien because the overpaid benefits were not traceable to an identifiable fund in Epolito's possession.
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