No Jury Trial For ERISA Claimants Who Characterized Their Claims As Legal, Not Equitable
It’s not unusual for an issue to come up in ERISA cases concerning whether the relief sought is legal or equitable, particularly following rulings in the past decade from the United States Supreme Court about the importance of such a distinction.
A recent opinion from a Missouri federal court illustrates the issue.
In United Mine Workers of America v. American Commercial Lines Transp., No. 4:08CV1777SNLJ, 2010 WL 2245084 (E.D. Mo. 2010), the plaintiff retirees and their union alleged that the plan made unlawful and unilateral modifications to the individual plaintiffs’ retirement medical benefits in a collective bargaining agreement.
The plaintiffs sought a declaratory judgment, injunctive relief, compensatory damages and “other relief” requiring the defendants to provide health benefits. The defendants moved to strike a jury demand, and the court granted the motion.
The defendants contended that the plaintiffs did not have a right to a jury trial under ERISA or any other grounds because they sought equitable, and not legal, relief. The plaintiffs argued that they sought to recover out-of-pocket medical expenses due to the unilateral modification of their health benefits, and also they contended that the action was one for breach of the collective bargaining agreement; accordingly, they argued that theirs was a legal action.
As the court pointed out, there is no right to a jury trial on ERISA claims. The plaintiffs argued, however, that Great-West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204, declared that an ERISA action seeking monetary damages is legal, and therefore triable by jury pursuant to the Seventh Amendment. The court disagreed with this characterization of Knudson, saying that the U.S. Supreme Court instead stated that restitution actions are “legal” when the plaintiff seeks to impose personal liability upon the defendant to pay a sum of money, whereas actions are “equitable” when they seek “to restore to the plaintiff particular funds or property in the defendant’s possession.” That is precisely the claim brought by plaintiffs, the U.A.W. court said, and therefore there was no right to a jury trial. The court also rejected the plaintiffs’ other arguments concerning a right to trial by jury, and granted the defendant’s motion.