18th Annual Workplace Class Action Report - 2022 Edition

342 Annual Workplace Class Action Litigation Report: 2022 Edition chose to remain enrolled. Id . at *5. The Court held that the Plan and other documents expressly reserved to Defendant the unilateral right to amend, modify, change, or terminate the Plan at any time and for any reason and to change its cost sharing coverage. Id . at *7. The Court held that Defendant provided a generous welfare benefits Plan for retirees and relied on its statutory right to modify and amend the Plan, while noting its understanding of that right in the written Plan documents. Id . The Court opined that even if Plaintiffs could establish a claim pursuant to the ERISA, they could not prove that they were entitled to a preliminary injunction at this stage of the proceedings. The Court held that Plaintiffs had no statutory right to the benefits provided under the previous welfare benefits Plan. Id . at *15. The Court further ruled that since Plaintiffs’ benefits were not vested, they were not entitled to the benefits of the previous Plan. Accordingly, the Court denied Plaintiffs’ motion for a preliminary injunction. Brass, et al. v. SPX Corp., 2021 U.S. Dist. LEXIS 21027 (W.D.N.C. Feb. 4, 2021). Plaintiffs, a group of retirees who formerly worked for Defendant, filed a class action lawsuit alleging that Defendant violated previously executed settlement agreements under § 301 of the Labor-Management Relations Act (“LMRA”) and violated their employee welfare benefit plans under the Employee Retirement Income Security Act (“ERISA”). Id. at *3. Specifically, in 2001, the United Auto Workers union and several retired SPX union members filed two class actions claiming that Defendant violated union members’ rights to lifetime health benefits. Id. at *4. The parties settled these actions in 2004 and executed settlement agreements in which Defendant committed to providing certain healthcare benefits to retirees and their spouses for the rest of their lives. The agreements also bound Defendant to provide Plaintiffs with “substantially equivalent” benefits at the same cost as its prior plan. Then, in 2014, Defendant adjusted the structure of its health benefits by implementing a healthcare reimbursement account plan (“HRA”) to replace its previous plan. Plaintiffs subsequently filed the present action in response to Defendant’s implementation of the HRA. Defendant filed a motion for summary judgment, while Plaintiffs filed a motion seeking partial summary judgment on their claims that the HRA was not “substantially equivalent” to the healthcare coverage guaranteed by the 2004 settlement agreements. The Court granted Defendant’s motion and denied Plaintiffs’ motion. As a threshold matter, the Court determined that “substantially equivalent,” as used in the settlement agreements, meant “benefits that are ‘largely but not wholly identical especially in effect or function’ to the benefits specified in the agreements.” Id. at *25. Plaintiffs argued that Defendant’s HRA system violated the settlement agreements because it was not a “plan” that provided “coverage.” Id. at *28-29. Plaintiffs relied on extrinsic evidence to support this interpretation, but because the Court found that HRAs clearly make coverage available through a funding mechanism, it determined that it did not need to consider Plaintiffs’ extrinsic evidence. Plaintiffs also contended that Defendant violated the settlement agreements by setting an annual limit of $5,000 on the credit for each retiree’s HRA account. However, the Court found that as long as Plaintiffs were not required to pay additional funds in excess of their credit limit, Defendant had complied with the settlement agreement. Plaintiffs likewise challenged the HRA system’s prescription drug coverage by claiming that it contained a coverage gap and thus was not substantially equivalent to Defendant’s prior plan. The Court noted that this issue depended on whether Plaintiffs’ actual net costs for the benefits increased, rather than any specific coverage gap. To that end, Plaintiffs pointed to two ways in which their healthcare net costs allegedly increased, including cost-related charges and the administrate burden posed by the HRA system. In terms of the actual costs, the Court held that Plaintiffs failed to provide sufficient evidence that “at least one Plaintiff was holistically required to be financially worse off under the HRA,” since Plaintiffs only offered evidence concerning particular areas of the HRA. Id. at *45. Regarding the administrative component of the HRAs, Plaintiffs averred that Defendant placed an administrative burden on retirees by forcing them to select their own plans. The Court opined, however, that such a claim required a showing of bad faith, and here, Defendant hired a company to assist Plaintiffs with selecting a plan and provided Plaintiffs with up to a year to seek reimbursement. Id. at *48. Therefore, the Court granted Defendant’s motion for summary judgment and dismissed Plaintiffs’ complaint with prejudice. Durnack, et al. v. Retirement Plan Committee Of Talen Energy, 2021 U.S. Dist. LEXIS 172853 (E.D. Penn. Sept. 13 2021). Plaintiffs, a group of retirement plan participants, filed a class action against Defendants alleging various claims under the ERISA arising out of the termination of Plaintiffs’ employment. Plaintiffs were all long-term, senior management employees of Pennsylvania Power and Light ("PPL") and its successor in various managerial capacities. Plaintiffs were eventually terminated and accepted severance packages, but claimed that they retired years earlier than they had planned and were owed additional retirement pension