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ERISA Watch – April 23, 2015

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This week’s notable decision is McDonough v. Aetna Life Ins. Co., 2015 WL 1684079 (1st Cir. Apr. 15, 2015), where the First Circuit found that Aetna abused its discretion when it denied Plaintiff’s long-term disability claim because it did not consider the material duties of Plaintiff’s particular position nor assessed how those duties align with the position as it is normally performed in the national economy.

This is an excellent decision for disability claimants, particularly those who work in occupations that are physically “sedentary,” but cognitively demanding and high-stress (as ERISA attorneys, we wouldn’t know what this is like). We often see claims denied because of a conclusory finding that one can do sedentary work, without any consideration of the material duties and cognitive requirements of the job. So, put your feet up and enjoy the rest of this week’s notable cases.

Your reliable source for summaries of recent ERISA decisions

Below is Kantor & Kantor LLP’s summary of this past week’s notable ERISA decisions.

First Circuit

Denial of severance benefits affirmed but interference claim remanded for consideration under appropriate summary judgment standard. In Niebauer v. Crane & Co., No. 14-2059, __F.3d___, 2015 WL 1787931 (1st Cir. Apr. 21, 2015), Plaintiff-Appellant Robert alleged that the administrator of his former employer’s executive severance plan denied him severance benefits after erroneously determining that he had retired voluntarily from his position. He also alleged that his former employer improperly interfered with his rights under the plan, in violation of 29 U.S.C. § 1140. After ordering additional discovery to fill in gaps in the administrative record, the district court granted the Defendants’ motion for summary judgment on both counts. The court held that arbitrary-and-capricious review applied, rejecting Plaintiff’s argument that the compensation committee’s interpretation of emails it considered, wherein Plaintiff discussed his retirement from Crane, is not subject to de novo review since simple fact-gathering cannot displace the deference owed to a plan administrator. The court also rejected Plaintiff’s argument that the committee’s decision was procedurally flawed by relying on an incomplete factual record and failing to comply with ERISA’s notice requirements. Because it found that the committee’s decision was supported by substantial evidence, the court affirmed the decision. With respect to the § 1140 claim, the district court’s analysis relied on the “substantial evidence” standard applicable to assessing denial-of-benefits claims under ERISA. In interference cases, the ultimate inquiry is whether the employment action was taken with the specific intent of interfering with the employee’s ERISA benefits. The typical summary judgment standard-under which evidence is reviewed in the light most favorable to the nonmoving party-applies in assessing interference claims. Therefore, the court remanded this claim to the district court for consideration under the appropriate standard of review.

Failure to consider material duties of “Own Occupation” is an abuse of discretion and $5,000 document penalty affirmed against Aetna. In McDonough v. Aetna Life Ins. Co., No. 14-1293, __F.3d___, 2015 WL 1684079 (1st Cir. Apr. 15, 2015), the First Circuit reversed the district court’s decision in favor of Aetna and found that Aetna abused its discretion by not considering the material duties of Plaintiff’s particular position and assessing how those duties align with the position as it is normally performed in the national economy. The court held that Aetna’s failure to articulate the contours of the own occupation standard, apply that standard in a meaningful way, and reason from that standard to an appropriate conclusion regarding the Plaintiff’s putative disability renders its benefits-termination decision arbitrary and capricious. None of the four internal reviewers upon whom Aetna relied compared Plaintiff’s symptoms or impairments to any description of the physical and cognitive demands of his own occupation. Aetna also never took the obligatory step of assessing whether and to what extent Plaintiff’s impairments compromised his ability to carry out the material duties of his own occupation as normally performed in the national economy. Because the court deemed this “a close case” with voluminous and conflicting medical evidence, it vacated the entry of summary judgment on the benefits-termination claim and remanded to the district court with instructions to remit the matter to Aetna for further review in light of the opinion. Lastly, the court affirmed the district court’s imposition of a $5,000 penalty pursuant to 29 U.S.C. § 1132(c)(1)(B), which averaged $4/day (instead of the available $110/day penalty) for each day the administrator was late in producing a plan document. The document was a policy agreement that contained discretionary language which impacted the standard of review. The court found that Plaintiff was not prejudiced by the late production and the administrator did not act in bad faith.

Fourth Circuit

Filing a complaint is appropriate procedure for seeking review of arbitration award in MPPAA proceeding. In Freight Drivers & Helpers Local Union No. 557 Pension Fund v. Penske Logistics LLC, No. 14-1464,__F.3d___, 2015 WL 1787776 (4th Cir. Apr. 21, 2015), the Fourth Circuit considered the question of how a party to an arbitration proceeding under the Multiemployer Pension Plan Amendments Act of 1980 (“MPPAA”) can obtain review of the arbitration order, as provided in 29 U.S.C. § 1401(b)(2). Specifically, the court addressed whether § 1401(b)(2) and § 1451 require the dissatisfied party to commence a civil action in a district court by filing a complaint, or whether § 1401(b)(3) requires the dissatisfied party to file an application for review of the arbitration order by filing a motion, as provided in the Federal Arbitration Act (“FAA”). In this case, the multiemployer pension plan sought to vacate or modify an arbitration order that rejected the Plan’s assessment of withdrawal liability with respect to two participating employers. The district court dismissed the action and denied reconsideration. The Fourth Circuiyt held that commencing an action by filing a complaint is the appropriate procedure for seeking review of an arbitration award entered pursuant to the MPPAA, and the amended complaint filed by the multiemployer pension plan related back to filing date of original complaint, thus rendering it timely.

Sixth Circuit

Affirmative defenses of laches and equitable estoppel are unavailable in ERISA § 515 collection action. In Operating Engineers Local 324 Health Care Plan v. G & W Const. Co., No. 12-1786, __F.3d___, 2015 WL 1758652 (6th Cir. Apr. 20, 2015), a lawsuit to recover delinquent fringe-benefit payments under a contract between Defendant and the Union, the Sixth Circuit considered whether § 515 of ERISA bars equitable defenses of laches, estoppel, and waiver. The Funds had moved to strike the affirmative defenses, which the district court denied, but certified the case for interlocutory appeal. The court held that laches cannot bar an action to collect unpaid monetary contributions owed to the Funds when the suit is brought under ERISA § 515 within the applicable statute of limitations. Because laches within the term of the statute of limitations is no defense at law to claims for monetary damages, the laches defense is insufficient as a matter of law under Rule 12(f). With respect to equitable estoppel against the Funds based on the Union’s alleged conduct of not seeking fringe benefits for nonunion members, the court held that the defense is barred by ERISA § 515 because equitable estoppel based on union conduct is not among the few defenses that may be raised to a collection action. Lastly, the court found that the Funds have not offered any “developed argumentation” on the waiver defense so the court declined to address whether it is appropriate to bar the affirmative defense of waiver in this ERISA § 515 collection action.

Ninth Circuit

Discretionary clause found only in the SPD is not sufficient to alter the standard of review from de novo. In Prichard v. Metro. Life Ins. Co., No. 12-17355, __F.3d___, 2015 WL 1783507 (9th Cir. Apr. 21, 2015), the Ninth Circuit held that the district court should have reviewed Plaintiff’s long-term disability claim de novo since the grant of discretion to MetLife was only in the SPD, which is not part of the Plan’s “written instrument.” The court found that the only document in the record that contains a clear indication that it is a Plan document is an insurance certificate that expressly states that the Plan consists only of (1) the Group Policy and its Exhibits, which include the certificate(s); (2) IBM’s application; and (3) any amendments and/or endorsements to the Group Policy. The insurance certificate declares that those documents constitute the “entire contract” between IBM and MetLife. The Ninth Circuit previously held in Grosz-Salomon v. Paul Revere Life Ins. Co., 237 F.3d 1154, 1161 (9th Cir. 2001) that a Plan document’s integration clause precluded the administrator from binding insureds to the Summary’s discretion-granting clause. Applying that principle to this case, and limiting the analysis to the documents listed in the insurance certificate’s integration clause, the court found that no written instrument of the Plan confers discretionary authority to MetLife.

Select Slip Copy & Not Reported Decisions

Attorneys’ Fees

In Delprado v. Sedgwick Claims Mgmt. Servs., Inc., No. 1:12-CV-00673 BKS, 2015 WL 1780883 (N.D.N.Y. Apr. 20, 2015), the court found that Plaintiff was entitled to attorneys’ fees after securing a decision finding her denial of benefits to be arbitrary and capricious and requiring remand.

In Greene v. Drobocky, No. 1:12-CV-00078-TBR, 2015 WL 1737772 (W.D. Ky. Apr. 16, 2015), the court denied the prevailing Defendant’s motion for attorneys’ fees. Although the court found that there can be no doubt that Defendant demonstrated success on the merits by winning summary judgment on all but one of Plaintiff’s claims and then prevailing on the remaining claim at trial, the court denied fees because Plaintiff did not bring the lawsuit with a culpable motive, it was unclear whether Plaintiff could satisfy a judgment, the court need not discourage plaintiffs from bringing such claims in the future (particularly in the absence of improper litigation tactics or otherwise vexatious acts), and Plaintiff’s claims were not frivolous.

In Kessler v. Aetna Health Inc., No. CV 14-00939(RGA), 2015 WL 1775529 (D. Del. Apr. 16, 2015) (Not Reported in F.Supp.3d), the court granted summary judgment to Aetna on Plaintiff’s denial of inpatient treatment claim for drug and alcohol addiction. Aetna moved for attorneys’ fees. In considering the five factors, the court found that: 1) Plaintiff does not have any level of culpability for bringing the action and there is no evidence at all of bad faith; 2) ability to satisfy an award weighs against awarding attorney’s fees since Plaintiff has received treatment multiple times for drug and alcohol addiction and it is highly unlikely that Plaintiff has any money to pay attorneys’ fees; 3) the deterrent effect weighs in favor of awarding attorney’s fees since Plaintiff brought this case without any medical opinion that inpatient treatment was medically necessary and there would be a deterrent effect on future plaintiffs considering bringing weak claims; 4) benefit to other members weighs against attorney’s fees; and 5) the merits of the position weighs in favor of awarding attorney’s fees since Plaintiff had no real basis for his claim. The court found that although factors three and five support awarding fees, the first, second, and fourth factors weigh against awarding fees. Accordingly, the court denied Aetna’s motion for fees even though Plaintiff did not respond to Aetna’s request.

In Trustees of Empire State Carpenters Annuity, Apprenticeship, Labor-Mgmt. Cooperation, Pension & Welfare Funds v. Penco United, LLC, No. 13-CV-4745 SJF AKT, 2015 WL 1650960 (E.D.N.Y. Apr. 14, 2015), a contributions collections matter, the court observed that recent prevailing hourly rates for attorneys practicing in the Eastern District of New York are: (a) between three hundred to four hundred fifty dollars ($300.00-$450.00) for partners in large law firms and attorneys with extensive litigation experience or significant experience in the particular area of law at issue. The court awarded an hourly rate of $250 for an attorney with over fifteen years of experience representing employee benefit plans for work done prior to March 1, 2013 and an hourly rate of $300 for work performed thereafter. For the attorney’s associates, the court awarded hourly rates of $200 and $225 (for work after March 1, 2013). The court awarded fees in the total amount of $5,000 and costs of $545.62.

Breach of Fiduciary Duty

In Greene v. Drobocky, No. 1:12-CV-00078-TBR, 2015 WL 1737772 (W.D. Ky. Apr. 16, 2015), Plaintiff filed a motion to alter or amend judgment pursuant to Rule 59(e), arguing that the court erred in finding that her employer was not a fiduciary, where Plaintiff alleged that the pension plan administrator removed Plaintiff as a plan participant via a handwritten alteration of the Adoption Agreement per her employer’s instruction. The court denied the motion, explaining that it will not depart from the clear precedent indicating that no breach of fiduciary claim arises when an employer acts as a settlor of the plan.

In Owens v. Metro. Life Ins. Co., No. 2:14-CV-00074-RWS, 2015 WL 1651125 (N.D. Ga. Apr. 14, 2015), Plaintiff brought a putative class action involving the issue of whether the creation of a “Total Control Account” to pay life insurance death benefits constitutes a breach of fiduciary duty. Plaintiff alleged the following causes of action: breach of the duty of loyalty imposed by ERISA § 404(a)(1)(A) (Count I); breach of the fiduciary duties imposed by ERISA § 406(b)(1) (Count II), § 406(a)(1)(B) (Count III), and § 406(a)(1)(C) (Count IV); declaratory relief regarding coverage by state insurance guaranty funds for the Georgia subclass (Count V); and postmortem interest for the Georgia subclass (Count VI). The court found that Plaintiff did not have constitutional standing to bring Count V and dismissed that claim. However, the court denied dismissal of the remaining claims, finding that this case more closely resembles Mogel v. Unum Life Insurance Co., 547 F .3d 23 (1st Cir.2008) rather than Merrimon v. Unum Life Ins. Co. of Am., 758 F.3d 46 (1st Cir.2014).

Disability Benefit Claims

In Delprado v. Sedgwick Claims Mgmt. Servs., Inc., No. 1:12-CV-00673 BKS, 2015 WL 1780883 (N.D.N.Y. Apr. 20, 2015), the court found that Defendants’ decision to deny Plaintiff’s first STD claim was reasonable based on Plaintiff’s unclear diagnosis at the time, but that its decision to deny Plaintiff’s second STD claim, after she was diagnosed with fibromyalgia, was arbitrary and capricious. Defendants committed myriad errors in making their decision, including not properly considering subjective symptoms of pain and fatigue and the opinions of the doctors who examined her, relying on a flawed report, failing to issue a formal determination letter regarding Plaintiff’s appeal, and failing to provide adequate notice of what information was necessary to show disability due to fibromyalgia. Defendants rejected the claim on the basis that Plaintiff had not satisfied the required waiting period, and therefore, the claim was never considered on the merits. Defendants’ own errors in deciding Plaintiff’s underlying second STD claim prevented Plaintiff from possibly satisfying the condition precedent of being found disabled for 180 days. The court remanded the claims to Defendants to consider all the relevant evidence under the appropriate standards but declined to order the matter stayed and retain jurisdiction during the remand.

In Denney v. Aetna Life Ins. Co., No. 2:14-CV-1519-JHH, 2015 WL 1734337 (N.D. Ala. Apr. 16, 2015), the court granted summary judgment in favor of Aetna on Plaintiff’s claim for “any occupation” disability benefits, where Plaintiff previously worked as a ramp agent for Southwest Airlines, a heavy duty-strength occupation. The court found that Aetna’s benefits decision, based on the FCE, an “independent” review of Dr. Ephraim Brenman, Plaintiff’s neurosurgeon’s medical records and release of Plaintiff to return to work, a CT myelogram and MRI scans, and transferable skills analysis, was correct.

In Avena v. UNUM Life Ins. Co. of Am., No. CIV.A. 13-5947, 2015 WL 1726173 (E.D. La. Apr. 15, 2015), Plaintiff claimed long-term disability benefits following his involvement in a car accident, which Unum denied. The court found that Unum did not err in failing to order an independent examination of Plaintiff. The court further found that Unum’s denial of benefits was not arbitrary and capricious, where, Plaintiff was able to work for several months after the accident; he attended a fishing trip after the accident; despite Plaintiff’s continued complaints of pain, recommended pain management was limited to as-needed use of the same conservative medications prescribed immediately after the accident; only one doctor placed restrictions or limitations on Plaintiff’s movement; further testing was not conducted despite Plaintiff’s continued complaints of pain; the reviewing doctors felt Plaintiff’s MRI results were consistent with age-related changes; Plaintiff provided no proof that he ever attended physical therapy; and the accident report indicated that the accident resulted in minor damages to both vehicles and emergency medical attention was not sought.

In Rodriguez v. Reliance Standard Life Ins. Co., No. 14-1986, 2015 WL 1727419 (3d Cir. Apr. 14, 2015), the Third Circuit affirmed the district court’s decision that Reliance Standard Life Insurance Company did not arbitrarily and capriciously determine that Plaintiff was ineligible to continue to receive long-term disability benefits. Reliance determined that Plaintiff was diagnosed with a mental or nervous disorder and that she did not meet the Plan’s definition of “totally disabled.” The court rejected Plaintiff’s argument that she was denied procedural due process because Reliance failed to inform her of the evidence required to perfect her appeal.

In Cox v. Allin Corp. Plan, No. C 12-5880 SBA, 2015 WL 1737764 (N.D. Cal. Apr. 14, 2015) (Not Reported in F.Supp.3d), the court denied the parties’ motions for reconsideration on its partial grant of Plaintiff’s motion for judgment, finding that Unum had abused its discretion in terminating Plaintiff’s benefits and remanding the matter to Unum for further consideration of Plaintiff’s claim. The court specifically found that Unum abused its discretion by failing to properly address the SSA’s decision and applying the incorrect standard to assess the applicability of the self-reported limitation. In view of those conclusions, the court found remand is the proper remedy rather than payment of benefits.

In Riley v. Aetna Life Ins. Co., No. 13-CV-01347-REB-KMT, 2015 WL 1726762 (D. Colo. Apr. 13, 2015) (Not reported in F.Supp.3d), the court found that Aetna’s decision to deny long-term disability benefits was supported by substantial evidence, including a medical review completed by Dr. Elana Mendelssohn, a psychologist. The court found that Plaintiff can perform the physical demands of sedentary work but rejected his claim that he cannot handle the stress of the managerial positions Aetna identified as ones he can perform. The court found that Dr. Mendelssohn’s conclusion that the record justifies no psychologically-related limitations on Plaintiff’s ability to work is more than sufficient to support Aetna’s conclusion that Plaintiff did not meet the enhanced definition of disability set forth in the plan.


In Everson v. Zurich Am. Ins. Co., No. 5:14-CV-613-OC-37PRL, 2015 WL 1708453 (M.D. Fla. Apr. 15, 2015), a lawsuit challenging the denial of accidental death benefits, the court denied Plaintiff’s motion to order Zurich to supplement the administrative record with documents submitted after it issued a decision on Plaintiff’s appeal. However, the court did permit Plaintiff to conduct limited discovery regarding the scope and impact of Zurich’s admitted conflict of interest.

In Greenbrier Hotel Corp. v. Unite Here Health, No. CIV.A. 5:13-11644, 2015 WL 1637754 (S.D.W. Va. Apr. 13, 2015), Plaintiffs filed a complaint alleging entitlement to excess contributions made to Plan 155, which Defendant refused to remit. The counts remaining following a motion to dismiss involve breach of fiduciary duty under ERISA. Plaintiff filed a motion to compel concerning several interrogatories and 56 different requests for production of documents, which the court granted in part. The category of documents Plaintiff sought included: 1) trust agreements, plan rules, SPDs, amendments, and communications concerning these documents; 2) termination of Plan unit 155; 3) documents related to the agreement between UNITE HERE and SEIU; 4) reserves; 5) collective bargaining negotiations and 2004 and 2009 plan documents; and 6) information on other Plan units.

ERISA Preemption

In Hechter v. Nationwide Fire Ins. Co., No. 2:14-CV-2720, 2015 WL 1757542 (S.D. Ohio Apr. 17, 2015), the court found that claims relating to OhioHealth’s alleged illegal billing practices, and DWA’s alleged cooperation with OhioHealth in furtherance of those billing practices are not completely preempted by ERISA. Plaintiff in this action brought claims against a third party hospital for breach of a preferred provider agreement and alleged that Defendants’ billing practices violated Ohio law. Plaintiff’s claims are concerned with the contractual relationship between her medical insurer and Defendants and do not seek to enforce rights under an employee benefit plan or to receive benefits. The court found no reason to exercise supplemental jurisdiction over the action and granted Plaintiff’s motion to remand.

In Cole v. Am. Specialty Health Network, Inc., No. 3:14-CV-02022, 2015 WL 1734926 (M.D. Tenn. Apr. 16, 2015), a lawsuit by health service providers alleging that they signed a three-page Election to Participate before receiving a 82-page contract or “Provider Services Agreement” (“PSA”) containing terms to which they did not agree, the court dismissed the claims for breach of contract/unjust enrichment, wrongful trover/conversion, constructive trust, negligence, negligence per se, and accounting as being preempted by ERISA because these claims allege that Cigna improperly calculated and/or denied benefits pursuant to the applicable benefit plans and “relate to” such plans. The court also found that the claims for constructive trust and accounting are remedies, not causes of action, and would be dismissed on that basis as well. Additionally, the negligence and negligence per se claims would also be dismissed because in Tennessee contractual duties do not give rise to a negligence claim. The court did not dismiss or find preempted Plaintiffs’ claim for contract of adhesion but did dismiss the fraud claim for not being pled with sufficient particularity.

In Terry v. Pepsi Bottling Grp. Inc. Long-Term Disability Plan, No. CIV. 15-7-ART, 2015 WL 1649126 (E.D. Ky. Apr. 14, 2015), the court found as not preempted Plaintiff’s lawsuit seeking to enforce the terms of a settlement agreement where the PBG Plan agreed that it will not seek nor be entitled to any recoupment/offset/reduction in regard to LTD benefits due to other benefits paid but later started to offset his LTD benefits by the amount he received in Social Security Disability benefits. The court held that Plaintiff alleges a breach of the settlement agreement-a purely state-law issue. As such, the court remanded the case to state court.

Life Insurance & AD&D Benefit Claims

In Mitchell v. Robinson, No. 1:11CV130 SNLJ, 2015 WL 1650871 (E.D. Mo. Apr. 14, 2015), the court held that MetLife’s decision to pay the decedent’s husband death benefits was supported by substantial evidence and granted summary judgment in its favor. In this case, Plaintiffs allege a claim of wrongful death against Robinson for killing the decedent; however, MetLife paid benefits to Robinson following an investigation where a police captain informed MetLife that Robinson was not the aggressor and inadvertently shot the decedent while trying to shoot at the person breaking into the residence.

Medical Benefit Claims

In Robertson v. Blue Cross & Blue Shield of Texas, No. CV 14-224-M-DWM, 2015 WL 1715072 (D. Mont. Apr. 15, 2015) (Not Reported in F.Supp.3d), Blue Cross denied preapproval for a hemapoietic stem cell transplant to treat Plaintiff’s diffuse systemic sclerosis, a rare autoimmune disease that causes the skin and other connective tissues in the body to tighten and harden. Without treatment, the disease can attack tissues in internal organs and is fatal once it infiltrates the tissues of the lungs or heart. Blue Cross determined that the procedure is “experimental, investigational, and unproven.” The evidence in the record showed that the procedure is not “standard therapy” for severe systemic sclerosis, is still under investigation, and is associated with treatment-related mortality, but is not “in general use in the medical community” for the treatment of systemic sclerosis. The court affirmed Blue Cross’s decision but, finding that it “was legally, but perhaps not morally, reasonable.”

Withdrawal Liability & Unpaid Benefit Contributions

Cascade Pension Trust v. Bob Fisher Elec., Inc., No. 6:14-CV-01920-MC, 2015 WL 1802217 (D. Or. Apr. 20, 2015) (granting default judgment of $117,474.90 in unpaid contributions; interest on the unpaid contributions equal to $24,643.08 as of December 1, 2014, plus an additional $38.6219 each day thereafter until paid in full; $24,643.08 in liquidated damages; $6839.20 in attorney’s fees, court costs, and audit costs, and interest on interest on these amounts from the date judgment is entered until paid in full at the rate of 0.24 percent per annum).

Buffalo Laborers Welfare Fund v. H&M Plumbing & Mech. Contracting Inc., No. 14-CV-960S, 2015 WL 1735198 (W.D.N.Y. Apr. 16, 2015) (granting default judgment and awarding Fund Plaintiffs $195,398.70 in delinquent fringe benefit contributions, $51,767.27 in interest, $51,767.27 in liquidated damages, and $5,525.57 in attorneys’ fees and costs; awarding Union $9,326.94 in dues checkoffs, $1,055.10 in NYLPAC contributions, and $2,110.20 in Construction Industry Fund contributions, as well as $2,978.63 in interest).

United Ass’n. of Plumbers & Steamfitters Local No. 22 v. H&M Plumbing & Mech. Contracting Inc., No. 14-CV-070S, 2015 WL 1735117 (W.D.N.Y. Apr. 16, 2015) (finding that the collective relief requested in the motion for a default judgment does not comport with the relief requested in connection with each of the three causes of action alleged in the Third Amended Complaint and denying motion for default judgment).

Trustees of the New Jersey B.A.C. Health Fund v. Org Contracting, No. CIV.A. 13-5854 MAS, 2015 WL 1730171 (D.N.J. Apr. 14, 2015) (granting default judgment to Plaintiff for Defendant’s failure to make contributions to Plaintiff pursuant to the CBA).

* Please note that these are only case summaries of decisions as they are reported and do not constitute legal advice. These summaries are not updated to note any subsequent change in status, including whether a decision is reconsidered or vacated. The cases reported above were handled by other law firms but if you have questions about how the developing law impacts your ERISA benefit claim, the attorneys at Kantor & Kantor LLP may be able to advise you so please contact us. Case summaries authored by Michelle L. Roberts, Partner, Kantor & Kantor LLP, 1050 Marina Village Pkwy., Ste. 105, Alameda, CA 94501; Tel: 510-992-6130.

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