Looking Past The Label For ERISA Claims
For some, it’s a question of trying to fit a square peg into a round hole. The fact is that claimants often characterize their ERISA claims as equitable rather than as legal claims.
A recent opinion from the Western District of Pennsylvania, Miller v. Mellon Long Term Disability Plan, Civil Action No. 09-1166, 2010 WL 2595568 (W.D. Pa. June 25, 2010), points out what has become a common admonition to look past the labels that plaintiffs give such claims:
In determining whether the requested relief is appropriately framed in equity for purposes of Section 1132(a)(3), the Supreme Court has cautioned that a court must look past the label attached by the plaintiff. In this regard, the Supreme Court further explained:
‘Almost invariably … suits seeking (whether by judgment, injunction, or declaration) to compel the defendant to pay a sum of money to the plaintiff are suits for “money damages,” as that phrase has traditionally been applied, since they seek no more than compensation for loss resulting from the defendant’s breach of legal duty.’
[Great West Life & Annuity Company v. Knudson, 534 U.S. 204, 210 (2002)) (quoting Bowen v. Massachusetts, 487 U.S. 879, 918-19 (1988) (Scalia, J., dissenting).
In Miller, the Court determined that, when it “looks past the label here, it is clear that the equitable relief requested by Plaintiff is essentially a claim for benefits expressed in equitable language.”