United States Courts of Appeals and ERISA Disability Claims
The United States courts of appeals (or circuit courts) are the intermediate appellate courts of the United States federal court system. That means they are the level between federal district courts and the Supreme Court of the United States. A court of appeals decides appeals from the district courts within the states in its federal judicial circuit.
The United States courts of appeals are considered among the most powerful and influential courts in the country. These courts have the ability to set legal precedent in regions that cover millions of American citizens. U.S. courts of appeals have a strong policy influence on U.S. law.
Because the U.S. Supreme Court only reviews less than 1% of the more than 10,000 cases filed with it each year, the United States courts of appeals serve as the final level of review in most federal cases. The Ninth Circuit is especially influential, covering approximately 20% of the American population.
There are thirteen United States courts of appeals in all, including:
- First Circuit Court of Appeals (Boston)
- Second Circuit Court of Appeals (New York City)
- Third Circuit Court of Appeals (Philadelphia)
- Fourth Circuit Court of Appeals (Richmond)
- Fifth Circuit Court of Appeals (New Orleans)
- Sixth Circuit Court of Appeals (Cincinnati)
- Seventh Circuit Court of Appeals (Chicago)
- Eighth Circuit Court of Appeals (St. Louis)
- Ninth Circuit Court of Appeals (San Francisco)
- Tenth Circuit Court of Appeals (Denver)
- Eleventh Circuit Court of Appeals (Atlanta)
- District of Columbia Circuit Court of Appeals (Washington)
- Federal Circuit Court of Appeals (Washington)
ERISA Disability Claims and Court of Appeals
ERISA is a federal act of law that is supposed to be a uniform body of law across the nation. Unfortunately, however, ERISA laws have not been interpreted by courts in a uniform fashion nationwide.
Statutory interpretation is the process by which courts interpret and apply legislation such as ERISA. (The terms statute, law and legislation all mean the same thing and are used interchangeably here). When a case involves law or statute, some amount of interpretation, or “reading between the lines”, is often necessary. That’s because the words of a statute sometimes have a plain and straightforward meaning. But in many other cases, there is an ambiguity (or vagueness) in the words of the statute that must be resolved by the court. To determine the meanings of statutes, courts utilize a variety of tools and methods of statutory interpretation, which may include a review of legislative history and purpose.
For our purposes here, ERISA statutes have not changed very much since the law was enacted in 1974. However, courts around the country have interpreted and applied that law differently in each jurisdiction. We all know that Supreme Court decisions on ERISA law are binding everywhere. However, each court of appeals’ decisions in ERISA cases are controlling only within the jurisdiction of that circuit. In numerous areas of ERISA law, the circuit courts have adopted different legal standards. Some circuits have a more favorable statutory interpretation for claimants, and others have a more favorable statutory interpretation for insurance companies.
In the blog section of this website, we will be highlighting court cases considering ERISA disability claims. I believe you will draw one major conclusion as you read ERISA disability court decisions – ERISA law heavily favors insurance companies and plans.
We must work within the legal framework of each circuit. Depending on the specific factual and legal issues in your individual claim, some circuits may offer more favorable statutory interpretation than others. That does not mean that one circuit is completely better than others. It does mean that one circuit would have been better with respect to the facts and legal issues in your case.
To make matters even more complicated, it helps to understand that the law is not the only issue that determines the outcome in litigation. Insurance companies may pay more for certain claims based on where you live. For example, generally speaking, cases in urban and coastal areas may pay higher settlement values than the same claim would have realized in the Midwest (say in Omaha, Kansas City, or Indianapolis).
The differences in statutory interpretation from circuit to circuit could be extremely important in your case. By now you may be wondering where you can file a lawsuit. There are three proper “venues” for filing an ERISA disability lawsuit: (1) the location where you live; (2) the location where your plan is administered (your employer is usually the officially designated plan administrator and the employer’s principal place of business is where the plan is administered); and 3) where some other defendant has its principal place in business (in most circuits the proper defendant in an ERISA disability benefits claim is the insurance company which issued the Long Term Disability policy). The best venue to file an ERISA Long Term Disability benefits claim is usually in the district court where you live. This may provide you with a subtle and unspoken “home field advantage”; the court may want to protect its resident over an outsider long term disability insurance company. In certain circumstances, however, you may be better off suing where your employer’s plan is administered – say in Nevada or California rather than in Louisiana (or wherever you live) because Ninth Circuit law (the law that controls in Nevada and California) may be more favorable to your case than Fifth Circuit law (which controls Louisiana).
The foregoing circuit summaries are generalities and are not intended to be comprehensive summaries of the law. These are basic observations about certain important features of ERISA law and practice in the various circuits. If you really want to understand where your case should be brought in the event of you need to sue your long term disability insurance company, consult an experienced ERISA attorney like Nick A. Ortiz.