ERISA-Seventh Circuit Holds That Plaintiff Adequately Alleged That She Is Eligible For Additional Payment For Services and Statutory Damages

In W.A. Griffin, M.D. v. Teamcare, No. 18-2374 (7th Cir. 2018), W.A. Griffin, M.D., is the assignee of her patient’s health plan, TeamCare (the “Plan”).  The Board of Trustees of Central States, Southeast and Southwest Areas Health and Welfare Fund (collectively “Central States”) administers the Plan.  ERISA governs the Plan.  Dr. Griffin sued Central States for underpayment and for statutory penalties based on its failure to furnish plan documents upon request.  The district court dismissed her complaint.

Upon reviewing the case, the Seventh Circuit Court of Appeals (the “Court”) found that Dr. Griffin adequately alleged that she is eligible for additional payment for services and statutory damages.  Accordingly, the Court affirmed the district court’s judgment only as to Count 2 (Central States breached its fiduciary duty by not adhering to the Plan’s terms), vacated the district court’s judgment as to Count 1 (Central States did not pay Dr. Griffin the proper rate for her services under the Plan) and Count 3 (Central States failed to produce, within 30 days, the summary plan description she requested, and certain other information), and remanded Counts 1 and 3 back to the district court for further proceedings.

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