Lessard v. Applied Risk Management
United States Court of Appeals for the Ninth Circuit
307 F.3d 1020 (2002)
- Written by Kelsey Libby, JD
Facts
Denice Lessard (plaintiff) worked as an analyst for Applied Risk Management (ARM) (defendant) in 1996. Lessard enrolled in an employee welfare-benefits plan administered by ARM. In October 1996, Lessard went on workers’-compensation leave following a work-related spine injury. Lessard remained on the welfare-benefits plan. Lessard underwent spinal-fusion surgery in January 1998 and never returned to work or sought employment after that time. In 1999, ARM entered an agreement with Professional Risk Management (PRM) (defendant), a subsidiary of MMI Companies, Inc. (MMI) (defendant) providing for the sale of ARM’s assets to PRM/MMI. Pursuant to the agreement, ARM employees automatically transferred to active employment with PRM and became covered by PRM’s welfare-benefits plan without interruption. However, in order to be eligible for transfer, the employee had to be actively employed or on an approved non-medical, non-extended leave of absence. Employees on medical, disability, workers’-compensation, or other extended leaves became eligible only if and when they returned to active employment. Six employees who were on extended leaves, mostly for medical or disability reasons, including Lessard, were excluded from transferring and receiving uninterrupted welfare benefits. Lessard brought suit under § 510 of the Employee Retirement Income Security Act (ERISA). The district court entered summary judgment in favor of ARM, PRM, and MMI, and Lessard appealed.
Rule of Law
Issue
Holding and Reasoning (Fletcher, J.)
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