At page 1072 Enforcing plan language over equitable common law theories45 citing caseswherein the court found that application of a common fund doctrine would undermine plan provisions requiring full reimbursement for medical benefits and that the plaintiff in thai matter had failed to show how such an application advanced the explicit statutory purpose of ERISA, namely to ensure th…
- Murray v. UNUM Life Ins. Co. of Am., No. 3:18-cv-00096 (W.D. Ky. Dec. 20, 2019).([T]he plain language of an ERISA plan should be given its literal and natural meaning.)
- Oliver Barber, III v. Lincoln Nat'l Life Ins. Co., No. 17-5588 (6th Cir. Jan. 23, 2018).unpublished([T]he plain language of an ERISA plan should be given its literal and natural meaning.)
- Elec. Energy, Inc. v. Lambert, 757 F. Supp. 2d 765 (W.D. Tenn. 2010).published (we find that [the equitable common fund doctrine] would undermine the express terms of the Plan that require full reimbursement for medical benefits.)
- Rice v. Jefferson Pilot Fin. Ins., 578 F.3d 450 (6th Cir. 2009).published (A primary purpose of ERISA is to ensure the integrity and primacy of the written plans.)
- Oakman v. Int'l United Auto. Aerospace & Agric. Workers, No. 1:23-cv-00026 (W.D. Ky. Aug. 6, 2025).“A primary purpose of ERISA is to ensure the integrity and primacy of the written plans”
- Presnal v. Dearborn Nat'l Life Ins. Co., No. 3:23-cv-00290 (N.D. Ind. Jan. 11, 2024).(affirming summary judgment and denying plaintiff’s request for equitable revision of defined plan terms)
- N.C. v. Premera Blue Cross, 667 F. Supp. 3d 1102 (W.D. Wash. 2023).published(A primary 5 purpose of ERISA is to ensure the integrity and primacy of the written plans” (citing Duggan v. 6 Hobbs, 99 F.3d 307 , 309–10 (9th Cir. 1996)). The Court consults the American Academy of 7 Child and Adolesc…)
- Smith v. Shoe Show, Inc., No. 1:20-cv-00813, 2022 WL 583569 (M.D.N.C. Feb. 25, 2022).Md. Sept. 10, 2021) (alteration in original) (quoting U.S. Airways, Inc. v. McCutchen, 569 U.S. 88, 100 (2013)), and thus plan fiduciaries must administer the Plan in accordance with the “literal and natural meaning” of Plan documents’ “pl…
- Sandra Peters v. Aetna Inc., 2 F.4th 199 (4th Cir. 2021).publishedAss’n, 391 F.3d 563, 568 (4th Cir. 2004) (“SPDs—Summary Plan Descriptions—are required by statute to ‘be written in a manner calculated to be understood by the average plan participant, and shall be sufficiently accurate and comprehensive…
- McWilliams v. Geisinger Health Plan, No. 4:20-cv-01236 (M.D. Pa. May 27, 2021). Plan v. Timms, 98 F.3d 971, 973 (7th Cir. 1996). consistent with ERISA.”92 Because “[a] primary purpose of ERISA is to ensure the integrity and primacy of the written plans . . . the plain language of an ERISA plan should be given its lite…
Show 33 more citing cases
- Counts v. United Of Omaha Life Ins. Co., 429 F. Supp. 3d 389 (E.D. Mich. 2019).published“plain language . . . should be given its literal and natural meaning”
- Witcher v. TeamCare, No. 2:18-cv-00022 (E.D. Ark. Oct. 17, 2019).Ordinarily, courts are to enforce the plain language of an ERISA plan “in accordance with ‘its literal and natural meaning.’” United McGill, 154 F.3d at 172 (quoting Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir. 1997)).
- McClure v. United Parcel Serv. Flexible Benefits Plan, 191 F. Supp. 3d 721 (W.D. Mich. 2016).published“[fjederal common law ... fills the gaps of ERISA’to assist in the interpretation of ERISA plans”
- Girl Scouts of Middle Tennessee, Inc. v. Girl Scouts of the U.S.A., 770 F.3d 414 (6th Cir. 2014).publishedSee Health Cost Controls v: Isbell, 139 F.3d 1070, 1072 (6th Cir.1997).
- Kenneth Fortier v. Principal Life Ins. Co., 666 F.3d 231 (4th Cir. 2012).published We have long held that, in the ERISA context, "the plain language of an ERISA plan must be enforced in accordance with ‘its literal and natural meaning.’" United McGill Corp. v. Stinnett, 154 F.3d 168, 172 (4th Cir. 1998) (quoting Health C…
- Isner v. Minnesota Life Ins. Co., 677 F. Supp. 2d 950 (E.D. Mich. 2009).publishedIn this regard, the Sixth Circuit in Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir.1997), held: “A primary purpose of ERISA is to ensure the integrity and primacy of the written plans.
- Longaberger Co. v. Kolt, 586 F.3d 459 (6th Cir. 2009).published Rather, such documents shall be executed only “as appropriate” and “as may be required to secure the Plan’s rights[.]” In Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir. 1997), we explained, “the plain language of an ERISA pl…
- McDevitt v. Reliance Stand. Life Ins., 663 F. Supp. 2d 419 (D. Md. 2009).publishedId. at 173 (quoting Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir.1997)).
- Klein v. Cent. States, Se. & Sw. Areas Health & Welfare Plan, 346 F. App'x 1 (6th Cir. 2009).unpublished“federal courts may not apply common law theories to alter the express terms of written benefit plans”
- McAfee v. Metro. Life Ins., 625 F. Supp. 2d 956 (E.D. Cal. 2008).publishedThus, the plain language of an ERISA plan should be given its literal and natural meaning.” Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir.1997) (citing Duggan v. Hobbs, 99 F.3d 307, 309-10 (9th Cir.1996)).
- Admin. Comm. of the Wal-Mart Stores, Inc. Assocs.' Health & Welfare Plan v. Shank Ex Rel. Shank, 500 F.3d 834 (8th Cir. 2007).published Ordinarily, courts are to enforce the plain language of an ERISA plan “in accordance with ‘its literal and natural meaning.’” United McGill, 154 F.3d at 172 (quoting Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir. 1997)).
- Clark v. Metro. Life Ins., 369 F. Supp. 2d 770 (E.D. Va. 2005).published The plain language of an ERISA plan must be enforced in accordance with “its literal and natural meaning.” Stinnett, 154 F.3d at 172 (quoting Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir.1997)).
- Mid Atl. Med. Servs., LLC v. Sereboff, 407 F.3d 212 (4th Cir. 2005).publishedTo achieve this objective, the “plain language of an ERISA plan must be enforced in accordance with ‘its literal and natural meaning.’ ” Id. (quoting Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir.1997)).
- Mid Atl. Med. Servs., LLC v. Joel Sereboff Marlene Sereboff, Sec'y of Labor, Amicus Supporting Mid Atl. Med. Servs., LLC v. Joel Sereboff Marlene Sereboff, Mid Atl. Med. Servs., LLC v. Joel Sereboff Marlene Sereboff, 407 F.3d 212 (4th Cir. 2005).publishedTo achieve this objective, the "plain language of an ERISA plan must be enforced in accordance with `its literal and natural meaning.'" Id. (quoting Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir.1997)).
- Kress v. Food Employers Labor Relations Ass'n, 391 F.3d 563 (4th Cir. 2004).publishedWe think, however, that the SPD clearly establishes the Fund's priority status. 17 We first turn to the plain language of the SPD to determine whether it in fact authorizes the Fund's actions. "[T]he plain language of an ERISA plan must be…
- Mank v. Green, 323 F. Supp. 2d 115 (D. Me. 2004).published“A primary purpose of ERISA is to ensure the integrity and primacy of the written plans ... [so that] the plain language of an ERISA plan should be given its literal and natural meaning”
- Fuller v. Liberty Life Assurance of Boston, 302 F. Supp. 2d 525 (W.D.N.C. 2004).publishedTo satisfy this objective, the plain language of an ERISA plan must be enforced in accordance with “its literal and natural meaning.” United McGill Corp. v. Stinnett, 154 F.3d 168, 172 (4th Cir.1998) (quoting Health Cost Controls v. Isbell…
- Sealy, Inc. v. Nationwide Mut. Ins., 286 F. Supp. 2d 625 (M.D.N.C. 2003).publishedSee United McGill Corp. v. Stinnett, 154 F.3d 168, 172 (4th Cir.1998) (“the plain language of an ERISA plan must be enforced in accordance with ‘its literal and natural meaning.’ ”) (quoting Health Cost Controls v. Isbell, 139 F.3d 1070, 1…
- Wausau Benefits v. Progressive Ins., 270 F. Supp. 2d 980 (S.D. Ohio 2003).published“One of the primary purposes of ERISA is to ensure the integrity and primacy of the written plans”
- Great-West Life & Annuity Ins. v. Bullock, 202 F. Supp. 2d 461 (E.D.N.C. 2002).published“ensure the integrity and primacy of the written plans”
- Karla SCHIKORE, Plaintiff-Appellee-Cross-Appellant, v. BANKAMERICA SUPPLEMENTAL Ret. PLAN, Defendant-Appellant-Cross-Appellee, 269 F.3d 956 (9th Cir. 2001).published “the plain language of an ERISA plan should be given its literal and natural meaning”
- Allison v. Wellmark, Inc., 153 F. Supp. 2d 1023 (N.D. Iowa 2001).published “A primary purpose of ERISA is to ensure the integrity and primacy of the written plans ... [so that] the plain language of an ERISA plan should be given its literal and natural meaning”
- Franks v. Prudential Health Care Plan, Inc., 164 F. Supp. 2d 865 (W.D. Tex. 2001).publishedSee e.g., Walker, 159 F.3d at 940 ; United McGill Corp. v. Stinnett, 154 F.3d 168, 172-73 (4th Cir.1998); Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir.1997); Bollman Hat Co. v. Root, 112 F.3d 113, 116-17 (3d Cir.), cert. de…
- Fairfield Mfg. Co. v. Hartman, 132 F. Supp. 2d 1142 (N.D. Ind. 2001).published“federal courts may not apply common law theories to alter the express terms of written benefit plans”
- Greenwood Mills, Inc. v. Burris, 130 F. Supp. 2d 949 (M.D. Tenn. 2001).published “when it is necessary to effectuate the purposes of ERISA”
- Paris v. Iron Workers Trust, No. 99-1558 (4th Cir. Apr. 17, 2000).unpublishedTherefore, "the plain language of an ERISA plan must be enforced in accordance with `its literal and natural meaning.'" Id. (quoting Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir. 1997)).
- Harris v. Harvard Pilgrim Health Care, Inc., 208 F.3d 274 (1st Cir. 2000).published See, e.g., Walker v. Wal-Mart Stores, Inc., 159 F.3d 938, 940 (5th Cir.1998); United McGill Corp. v. Stinnett, 154 F.3d 168, 172-73 (4th Cir.1998); Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir.1997); Bollman Hat Co. v. Root…
- Trujillo v. Cyprus Amax Minerals Co. Ret. Plan Comm., 203 F.3d 733 (10th Cir. 2000).published(holding that ERISA plan’s right to reimbursement for medical benefits was not subject to equitable reduction for proportional share of participant’s legal costs in obtaining third-party recovery)
- Cagle v. Ford, 59 F. Supp. 2d 548 (E.D.N.C. 1999).published “its literal and natural meaning”
- United McGill Corp v. Stinnett, No. 97-1046 (4th Cir. Aug. 27, 1998).published “its literal and natural meaning”
- United McGill Corp. v. Sharon Stinnett, 154 F.3d 168 (4th Cir. 1998).published “its literal and natural meaning”
- Sollars v. Healthcare Recoveries, 2006 OK CIV APP 140, 147 P.3d 289.published(wherein the court found that application of a common fund doctrine would undermine plan provisions requiring full reimbursement for medical benefits and that the plaintiff in thai matter had failed to show how such an a…)
- Zurich Am. Ins. v. O'Hara, 604 F.3d 1232 (11th Cir. 2010).published(where ERISA-regulated employee health benefits plan "expressly require[d] full reimbursement of the Plan for medical benefits when a beneficiaiy recovers sufficient damages from a third party tortfeasor,” and beneficiar…)
At page 1071 Limiting insurance reimbursement to lesser of amounts paid5 citing cases[I]n no event will the amount of reimbursement to the Insurance Company exceed the lesser of: 1. The amount actually paid under the Plan....
- Cent. States, Se. & Sw. Areas Health & Welfare Fund v. Haynes, No. 1:17-cv-06275 (N.D. Ill. July 19, 2019).Comm. of Wal-Mart Stores, Inc. Associates’ Health & Welfare Plan v. Gamboa, 479 F.3d 538, 545 (8th Cir. 2007) (quoting Health Cost Controls of Illinois, Inc. v. Washington, 187 F.3d 703, 712 (7th Cir. 1999)); Kress v. Food Employers Labor…
- Harris v. Harvard Pilgrim Health Care, Inc., 208 F.3d 274 (1st Cir. 2000).published See, e.g., Walker v. Wal-Mart Stores, Inc., 159 F.3d 938, 940 (5th Cir.1998); United McGill Corp. v. Stinnett, 154 F.3d 168, 172-73 (4th Cir.1998); Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir.1997); Bollman Hat Co. v. Root…
- Cagle v. Ford, 59 F. Supp. 2d 548 (E.D.N.C. 1999).published To satisfy this objective, the plain language of an ERISA plan must be enforced in accordance with “its literal and natural meaning.” Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir.1997).
- United McGill Corp v. Stinnett, No. 97-1046 (4th Cir. Aug. 27, 1998).published To satisfy this objec- tive, the plain language of an ERISA plan must be enforced in accordance with "its literal and natural meaning." Health Cost Con- trols v. Isbell, 139 F.3d 1070, 1072 (6th Cir. 1997).
- United McGill Corp. v. Sharon Stinnett, 154 F.3d 168 (4th Cir. 1998).published To satisfy this objective, the plain language of an ERISA plan must be enforced in accordance with “its literal and natural meaning.” Health Cost Controls v. Isbell, 139 F.3d 1070, 1072 (6th Cir.1997).
Other citing cases
- Culp, Inc. v. Cain, 414 F. Supp. 2d 1118 (M.D. Ala. 2006).published
- Hillenbrand v. Meyer Med. Grp., SC, 720 N.E.2d 287 (Ill. App. Ct. 1st Dist. 1999).published
v.
Ralph ISBELL, Father and Next Friend of Tammy Isbell, Defendant-Appellant
OPINION
SUHRHEINRICH, Circuit Judge.Defendant-Appellant, Ralph Isbell, appeals the grant of summary judgment for Plaintiff Health Cost Controls (“HCC”), the legal agent of an ERISA plan (the “Plan”) administrator. HCC sued Isbell for reimbursement of medical benefits the Plan provided for Isbell’s dependent daughter, a Plan beneficiary, after she recovered from a third party tortfeasor for her injuries. Isbell asserted an offset to the reimbursement for his legal costs attributable to recovery of the medical benefits. The district court found for HCC, holding that the terms of the Plan required full reimbursement and did not otherwise apportion attorney’s fees. The district court also reasoned that state common law and general principles of equity should not undermine the express language of an ERISA plan. We AFFIRM.
I. BACKGROUND
Isbell is a member of a self-funded employee group medical plan administered by Continental Assurance Company (“CNA”). Is-bell’s daughter, a dependent beneficiary of the Plan, was injured in an accident and received $145,000 of medical benefits from the Plan. Defendant then sued the third-party tortfeasor and settled for $1,000,000. CNA knew of the suit but did not intervene.
After Isbell settled, he did not voluntarily reimburse the Plan. Rather, HCC, representing CNA, sued Isbell for reimbursement of the medical benefits. HCC relied on the Plan’s reimbursement provision, which required a beneficiary to agree to reimburse the Plan for benefits for which a third-party may be liable. The Plan specified:
[I]n no event will the amount of reimbursement to the Insurance Company exceed the lesser of:
1. The amount actually paid under the Plan, or
2. The amount actually recovered from that part of the judgment or settlement in excess of the amount necessary to fully reimburse the Employee or dependent for out-of pocket expenses incurred, including attorney fees.
Initially, the district court reduced HCC’s reimbursement claim from $145,000 to about $86,500, holding that the Plan must bear a proportional share of the legal expenses that Isbell incurred. The district court reasoned that without Isbell’s legal expenses the Plan would not have been reimbursed at all and that it was only fair that the Plan share in the costs. On rehearing, however, the district court reversed itself and did not apportion the attorney’s fees because the Plan did not specifically provide for it. The district court relied upon Ryan by Capria-Ryan v. Federal Express Corp., 78 F.3d 123, 127-28 (3rd Cir.1996), where plan participants incurred legal expenses in prosecuting medical malpractice claims and attempted to reduce their reimbursement obligation under the[*1072] subrogation provision of their plan. The participants argued that the benefit plan would be unjustly enriched by their efforts if there were no pro rata offsets from the reimbursement to reflect their legal expenses. The Ryan court held that an ERISA plan participant could not offset for attorney’s fees where the plan unambiguously required full reimbursement. Isbell appealed.
II. DISCUSSION
This Court must decide whether HCC’s right to reimbursement should be equitably reduced by a proportional share of Isbell’s legal costs in obtaining the recovery from which Isbell will reimburse HCC. Unlike state courts, federal courts are “not general common-law courts and do not possess a general power to develop and apply their own rules of decision.” Tassinare v. American Nat’l Ins. Co., 32 F.3d 220, 225 (6th Cir.1994), (quoting Milwaukee v. Illinois, 451 U.S. 304, 312, 101 S.Ct. 1784, 1789-90, 68 L.Ed.2d 114 (1981)). Congress intended that the judiciary would develop and apply federal common law for ERISA claims. Weiner v. Klais & Co., 108 F.3d 86, 92 (6th Cir.1997). “In the realm of pensions, federal common law has only been ‘fashion[ed] ... when it is necessary to effectuate the purposes of ERISA.’ ” Tassinare, 32 F.3d at 225 (quoting Singer v. Black & Decker Corp., 964 F.2d 1449, 1452 (4th Cir.1992). A primary purpose of ERISA is to ensure the integrity and primacy of the written plans. Duggan v. Hobbs, 99 F.3d 307, 309-10 (9th Cir.1996); Van Orman v. American Ins. Co., 680 F.2d 301, 312 (3d Cir.1982). Thus, the plain language of an ERISA plan should be given its literal and natural meaning. Burnham v. Guardian Life Ins. Co., 873 F.2d 486, 489 (1st Cir.1989). Federal common law also fills the gaps of ERISA to assist in the interpretation of ERISA plans. Pilot Life Ins. Co. v. Dedeaux, 481 U.S. 41, 56, 107 S.Ct. 1549, 1557-58, 95 L.Ed.2d 39 (1987). However, federal courts may not apply common law theories to alter the express terms of written benefit plans. Bollman Hat Co. v. Root, 112 F.3d 113, 116 (3rd Cir.1997); Cinelli v. Security Pacific Corp., 61 F.3d 1437, 1444-45 (9th Cir.1995); Parker v. BankAmerica Corp., 50 F.3d 757, 769 (9th Cir.1995); Singer, 964 F.2d at 1452; Land v. Chicago Truck Drivers, Helpers, and Warehouse Workers Union (Independent) Health and Welfare Fund, 25 F.3d 509, 511 (7th Cir.1994).
Here, the Plan expressly requires Ml reimbursement of the Plan for medical benefits when a beneficiary recovers sufficient damages from a third party tortfeasor. Further, the Plan does not offset the reimbursement by the beneficiary’s legal costs attributable to recovery of the medical benefits. Thus, Is-bell does not have an affirmative contractual right under the Plan to a set-off for legal costs attributable to recovering the amount of the medical benefits. Moreover, Isbell has not identified to this Court that application of a set-off under a equitable common fund doctrine would advance any explicit statutory purpose of ERISA. Rather, we find that it would undermine the express terms of the Plan that require full reimbursement for medical benefits.
Accordingly, we AFFIRM the district court.