Opinion
Civil Action No. 3:05CV-186-R.
April 10, 2006
MEMORANDUM OPINION
This matter is before the Court on cross-motions of Defendant SCI Management Corporation and Plaintiff Sharon Mitchell for summary judgment(Dkt. Nos. 14 and 17). This matter is now ripe for adjudication. For the reasons that follow, the Court GRANTS the Defendant's motion and DENIES the Plaintiff's.
BACKGROUND
Plaintiff Sharon Mitchell filed this action for judgment against Liberty Mutual Life Assurance Corporation ("Liberty Mutual") and SCI Management Corporation ("SCI Management") for allegedly wrongful termination of long-term disability benefits that had previously been paid to her under a group disability plan sponsored by her employer ("Plan"). The Plan is governed by the Employee Retirement Income Security Act of 1974 ( 29 USC §§ 1001 et. seq.) ("ERISA"). On December 2, 2005, Plaintiff filed a motion seeking summary judgment on her claims. On January 12, 2005, SCI Management responded to Plaintiff's motion, and filed its cross-motion seeking summary judgment. On January 25, 2006, the Court entered an agreed order dismissing Plaintiff's claims against Liberty Mutual, as well as Liberty Mutual's claims against Plaintiff, with prejudice as a result of a settlement agreement between those two parties. Mitchell's claims against SCI Management, then, are the only ones that remain in the case.
The Court notes that a substantive review of Mitchell's claims under the Plan would be governed by the procedure set forth in Wilkins v. Baptist Healthcare Systems, Inc. 150 F.3d 609, 617 (6th Cir. 1998), not the traditional summary judgment standard.
Mitchell worked as an assistant Sales Manager for a funeral services company in Virginia named SCI Virginia Funeral Services, Inc. (d/b/a Mt. Comfort Cemetery) ("SCI Virginia"). SCI Virginia is an indirect subsidiary of Service Corporation International. SCI Management (corporate name SCI Funeral Cemetery Purchasing Cooperative, Inc.) is also an indirect subsidiary of Service Corporation International. It has a contract to provide SCI Virginia with human resources, legal, accounting and financial advice. Both SCI Management and SCI Virginia were sponsors of the ERISA plan in question. Liberty Mutual issued and administered the plan; under the terms of the plan, sole discretion to grant or deny benefits rested with Liberty Mutual.
DISCUSSION
SCI Management's summary judgment motion rests on the grounds that it cannot be liable to Mitchell under ERISA because, although it sponsored the plan in question, it was not her employer and in any case played no role in the decision to terminate her benefits. Because the Court agrees, it is unnecessary to reach the substance of Plaintiff's summary judgment motion (namely, the issue of whether the termination of her benefits violated ERISA).
From the corporate structure outlined above, it does not appear that SCI Management could be considered Plaintiff's employer. Even if it were, however, well-established Sixth Circuit precedent indicates that "[u]nless an employer is shown to control administration of a plan, it is not a proper party defendant in an action concerning benefits." Daniel v. Eaton Corp., 839 F.2d 263, 266 ( citing Boyer v. J.A. Majors Company Employees' Profit Sharing Plan, 481 F.Supp. 454, 457-58 (N.D. Ga. 1979)) (6th Cir. 1988). Although SCI Management was a sponsor of the Plan, no language in the Plan contemplates a role for the sponsors in making benefit determinations. Rather, the policy provides in Section 7 that "Liberty shall possess the authority, in its sole discretion, to construe the terms of this policy and to determine benefit eligibility hereunder. Liberty's decisions regarding construction of the terms of this policy and benefit eligibility shall be conclusive and binding." (Policy, Attachment # 1 to Dkt. # 14, at 33). Plaintiff has presented no evidence to suggest that SCI Management played any role in her benefits determination. Therefore, it is not a proper defendant in this action.
CONCLUSION
For the reasons outlined above, the Defendants' motion for summary judgment is GRANTED. Plaintiff's motion for summary judgment is DENIED. The case shall be DISMISSED. An appropriate order shall issue.