Santana v. Deluxe Corp.

17 Citing cases

  1. Mass. Laborers' Health & Welfare Fund v. Blue Cross Blue Shield of Mass.

    Civil Action 21-10523-FDS (D. Mass. Mar. 30, 2022)   Cited 1 times

    ; In re Express Scripts/Anthem ERISA Litig., 285 F.Supp.3d 655, 679 (S.D.N.Y. 2018) (stating that when “a service provider . . . acts pursuant to the terms of a contract, it does not exercise discretionary authority”); Santana v. Deluxe Corp., 920 F.Supp. 249, 254 (D. Mass. 1996) (stating that courts have “universally ruled” that when a third-party administrator does not adjudicate claims it is not an ERISA fiduciary); but see Technibilt Grp. Ins. Plan v. Blue Cross & Blue Shield of N.C., 438 F.Supp.3d 599, 605 (W.D. N.C. 2020) (denying motion to dismiss because allegations that Blue Cross exercised discretion in processing and paying claims were 17 sufficient to plausibly allege that Blue Cross functioned as plan fiduciary). Nonetheless, a third-party administrator may incur fiduciary responsibilities if it exercises other types of discretionary authority.

  2. Boucher v. Williams

    13 F. Supp. 2d 84 (D. Me. 1998)   Cited 29 times
    Holding that plan is not a "person" for the purposes of fiduciary liability under ERISA § 404

    A. Are Defendants Fiduciaries? The fiduciary duties imposed by ERISA § 404 apply only to those properly classified as fiduciaries. 29 U.S.C. § 1104; Santana v. Deluxe Corp., 920 F. Supp. 249, 253 (D.Mass. 1996). Defendants argue that neither the Fund nor IPI are "fiduciaries," and that they are therefore entitled to summary judgment on Count I, at least insofar as it applies to the forfeiture of allocation accounts.

  3. Terry v. Bayer Corp.

    145 F.3d 28 (1st Cir. 1998)   Cited 275 times
    Holding that review process is sufficient if denial letter defines plan's disability standard, states specific reasons for denying claim and, if plan administrator is in direct contact with claimant, assuring understanding

    With narrow exception, however, ERISA does not authorize actions against nonfiduciaries of an ERISA plan." Santana v. Deluxe Corp., 920 F. Supp. 249, 253 (D. Mass. 1996). See Mertens v. Hewitt Assocs., 508 U.S. 248, 262-63 (1993); Reich v. Rowe, 20 F.3d 25, 29 (1st Cir. 1994) (nonfiduciary liability limited to those "who commit violations of ERISA or who are engaged in an 'act or practice' proscribed by the statute").

  4. Shea v. Unum Life Ins. Co. of Am.

    Civil Action 24-cv-10402-ADB (D. Mass. Oct. 28, 2024)   Cited 1 times

    With narrow exception, however, ERISA does not authorize actions against nonfiduciaries of an ERISA plan.” Terry v. Bayer Corp., 145 F.3d 28, 35 (1st Cir. 1998) (quoting Santana v. Deluxe Corp., 920 F.Supp. 249, 253 (D. Mass. 1996)). A person (which includes various business entities, see 29 U.S.C. § 1002(9)) can be a fiduciary under ERISA in two ways.

  5. Steve C. v. Blue Cross & Blue Shield of Mass., Inc.

    450 F. Supp. 3d 48 (D. Mass. 2020)   Cited 4 times
    Concluding that determination of an appropriate analog for a Parity Act claim cannot be analyzed at the Rule 12 stage and likely requires discovery

    With narrow exception, however, ERISA does not authorize actions against nonfiduciaries of an ERISA plan." Terry v. Bayer Corp., 145 F.3d 28, 35 (1st Cir. 1998) (quoting Santana v. Deluxe Corp., 920 F. Supp. 249, 253 (D. Mass. 1996) ). When determining whether a party is a plan fiduciary, the Court must determine whether the defendant "undertakes discretionary tasks related to the plan's management and administration."

  6. Vendura v. Northrop Grumman Corp.

    CIVIL ACTION NO. 14-10943-WGY (D. Mass. Oct. 16, 2015)

    In holding that ERISA did not permit the plaintiff to sue this third party, the First Circuit noted that "[w]ith narrow exception, . . . ERISA does not authorize actions against nonfiduciaries of an ERISA plan." Id. (quoting Santana v. Deluxe Corp., 920 F. Supp. 249, 253 (D. Mass. 1996) (Freedman, J.)) (internal quotation marks omitted).

  7. Spinal Imaging, Inc. v. Aetna Health Mgmt. LLC

    Civil No. 09-11873-LTS (D. Mass. Mar. 26, 2014)   Cited 2 times

    With narrow exception, however, ERISA does not authorize actions against nonfidcuiaries of an ERISA plan.'" Terry v. Bayer Corp., 145 F.3d 28, 35 (1st Cir. 1998) (quoting Santana v. Deluxe Corp., 920 F. Supp. 249, 253 (D. Mass. 1996)). "Courts have determined that when the plan administrator retains discretion to decide disputes, a third party service provider . . . is not a fiduciary of the plan, and thus not amenable to a suit" under ERISA.

  8. Gómez-González v. Rural Opportunities, Inc.

    658 F. Supp. 2d 325 (D.P.R. 2009)   Cited 7 times

    It does not, however, in most situations, "authorize actions against nonfiduciaries of an ERISA plan." Terry v. Bayer Corp., 145 F.3d 28, 35-36 (1st Cir. 1998) (quoting Santana v. Deluxe Corp., 920 F.Supp. 249, 253 (D.Mass. 1996)); see also Reich v. Rowe, 20 F.3d 25, 29 (1st Cir. 1994) (nonfiduciary liability limited to those "who commit violations of ERISA or who are engaged in an 'act or practice' proscribed by the statute"); Negrón-Fuentes v. UPS Supply Chain Solutions, 532 F.3d 1, 10 (1st Cir. 2008) ("And an employer who is not an administrator is not otherwise a proper defendant in an ERISA benefits action.") (citing Beegan v. Assoc. Press, 43 F.Supp.2d 70, 73 (D.Me. 1999)).

  9. W.E. Aubuchon Co. v. BeneFirst, LLC

    661 F. Supp. 2d 37 (D. Mass. 2009)   Cited 7 times
    Listing “investigation of subrogation claims” as an activity requiring “the exercise of substantial discretion”

    As noted above, this case involves a state law contract claim by a plan against a third-party administrator. Certain types of claims against third-party administrators and other outside service providers — who are normally not "fiduciaries" within the meaning of ERISA — have been deemed to be preempted, while others have not. As a general rule, claims brought by participants or beneficiaries seeking to recover damages for failure to receive anticipated benefits have been found to be preempted. See, e.g., McMahon v. Digital Equip. Corp., 162 F.3d 28 (1st Cir. 1998) (breach of contract and tort claims against third-party administrator); Santana v. Deluxe Corp., 920 F. Supp. 2d 249, 257 (D. Mass. 1996) (breach of contract claim against third-party administrator); Toomey v. Jones, 855 F. Supp. 2d 19, 27 (D. Mass. 1994) (breach of contract and misrepresentation claims against consulting firm that provided administrative and other services). State law claims by participants or beneficiaries against employers or plans seeking to recover benefits have been routinely held to be preempted. See, e.g., Zipperer, 493 F.3d at 50 (claim against former employer for erroneous calculation of early retirement benefit); Carlo, 49 F.3d 790 (same); Vartanian v. Monsanto Co., 14 F.3d 697 (1st Cir. 1994) (claim against former employer for misrepresentation of early retirement benefits); see also Aetna Health, 542 U.S. 200 (state law claims against HMOs by plan participant alleging negligence in handling coverage decisions held to be preeempted).

  10. Hernandez v. National Life Insurance Co.

    Civil No. 04-1096 (HL) (D.P.R. Jun. 12, 2005)

    With narrow exception, however, ERISA does not authorize actions against nonfiduciaries of an ERISA plan." Terry 145 F.3d at 35 (citing Santana v. Deluxe Corp., 920 F.Supp. 249, 253 (D.Mass. 1996). These exceptions for nonfiduciary liability are limited to those "who commit violations of ERISA or who are engaged in an `act or practice' proscribed by the statute."