Grove v. Reliance Standard Insurance Life Insurance Company
ORDER granting 19 Defendant's Motion to Dismiss and Motion to Strike. Plaintiff's Second Cause of Action for Breach of Contract as set forth in the Complaint is DISMISSED with prejudice, and Plaintiff's jury trial demand is STRICKEN from the Complaint. Signed by Judge Candy W. Dale. (klw)
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF IDAHO
Case No. 3:21-cv-00222-CWD
INSURANCE LIFE INSURANCE
Before the Court is Defendant’s Motion to Dismiss Plaintiff’s Second Cause of
Action and to Strike Plaintiff’s Jury Demand. (Dkt. 19.) The motion is fully briefed and,
upon review, the Court finds the facts and legal arguments are adequately presented in
the briefs and record, without oral argument. Dist. Idaho Loc. Civ. R. 7.1(d). The motion
will be granted as explained below.
Plaintiff filed a two count complaint on May 21, 2021. Plaintiff contends
Defendant wrongfully terminated payments to her under its long-term disability policy,
effective August 23, 2019, on the grounds Plaintiff was no longer totally disabled
according to the policy terms.
ORDER - 1
Plaintiff’s first cause of action is a claim for wrongful denial of benefits under the
Employee Retirement Income Security Act (ERISA), 29 U.S.C. § 1132. She claims
“damages” as allowed under the Policy. Plaintiff’s second cause of action is for breach of
contract. She claims Defendant “breached the policy in denying Plaintiff continued
insurance benefits under the policy,” and again seeks “damages.” The prayer for relief
claims Plaintiff is entitled to “damages, in the form of unpaid disability insurance
payments.” She demands a trial by jury. (Dkt. 1.)
Defendant moves to dismiss the claim for breach of contract on the grounds it is
preempted by ERISA, and moves to strike the demand for a trial by jury, on the grounds
that ERISA does not afford a right to a jury trial. Plaintiff’s opposition to the motion
opens with a concession that her state law claim is preempted by 29 U.S.C. § 1132(a), but
next complains that, by doing so, ERISA strips her of her right under the Seventh
Amendment to the United States Constitution to a trial by jury and denies her right to
bring a legal claim for breach of contract for “damages beyond unpaid benefits.”
Plaintiff’s arguments are not well taken. 1
According to well-settled law, Plaintiff’s breach of contract claim is completely
preempted by ERISA. The purpose of ERISA is to provide a uniform regulatory regime
over employee benefit plans, and thus includes “expansive pre-emption
provisions…intended to ensure that employee benefit plan regulation would be
‘exclusively a federal concern.’” Aetna Health Inc. v. Davila, 542 U.S. 200, 208 (2004);
Upon initial review of the motion, the Court reasonably expected Plaintiff would request amendment of
her Complaint rather than challenge long-established law and precedent that this Court must follow.
ORDER - 2
ERISA § 514, 29 U.S.C. § 1144. Any state-law cause of action that “duplicates, or
supplants the ERISA civil enforcement remedy conflicts with the clear congressional
intent to make the ERISA remedy exclusive and is therefore preempted.” Davila, 542
U.S. at 209. Suits brought by a participant or beneficiary of a plan pursuant to ERISA
§ 502(a)(1)(B) to recover benefits due to her under the plan, to enforce her rights under
the terms of the plan, or to clarify rights to future benefits under the terms of the plan, fall
within ERISA’s ambit. Any other cause of action asserted seeking the same relief falls
within the scope of the ERISA civil enforcement mechanism, and is therefore preempted.
Davila, 542 U.S. at 210. Plaintiff’s breach of contract claim is duplicative of her claim
brought pursuant to ERISA, as it seeks to recover benefits due under the terms of the
plan, It is preempted.
Despite Plaintiff’s claim to damages beyond unpaid benefits, Plaintiff does not
state a cause of action independent of any legal duty under ERISA. According to the
allegations in the complaint, the contractual duty to pay benefits does not arise
independently of ERISA or the plan. Plaintiff has not alleged the existence of any
contract other than the benefit plan under which she claims entitlement to continued
benefit payments pursuant to the plan terms. Liability therefore exists, according to the
allegations in the Complaint, only because of the rights and obligations established by the
plan. Plaintiff’s complaint does not attempt to remedy any violation of legal duty or
contractual obligation independent of ERISA. Accordingly, Plaintiff’s claims for
damages fall entirely within the scope of ERISA § 502(a)(1)(B). See Davila, 542 U.S. at
213 – 21 (explaining that a plaintiff’s state law claims seeking remedies beyond those
ORDER - 3
authorized by ERISA were preempted when liability derives solely from the rights and
obligations established by the benefit plan).
There is no right to trial by jury under ERISA. The United States Court of Appeals
for the Ninth Circuit explained in Thomas v. Oregon Fruit Prod. Co. that its prior
decision in Spinelli v. Gaughan reaffirmed the long standing principle that plan
participants and beneficiaries are not entitled to jury trials for claims brought under, or
preempted by, Section 502 of ERISA. Thomas, 228 F.3d 991, 996 (9th Cir. 2000) (citing
Spinelli v. Gaughan, 12 F.3d 853 (9th Cir. 1993)). Every other circuit that has considered
the issue has reached the same conclusion as the Ninth Circuit did in Spinelli, and
reaffirmed in Thomas – if the nature of the issues involved and the remedy sought are
limited to the remedies set forth in ERISA § 502(a)(1)(B) or any other applicable
subsection of section 502, the claims are equitable in nature, and no right to a jury trial
attaches to them. Thomas, 228 F.3d at 996 (citing cases).
Plaintiff brings her claim pursuant to ERISA § 502, 29 U.S.C. § 1132, claiming
wrongful denial of benefits. Compl. ¶¶ 12-14. She seeks “injunctive relief” and recovery
of “unpaid disability insurance benefits.” Compl. at 1, 6, and ¶ 13. Her claims therefore
fall within ERISA §§ 502(a)(3) and 502(a)(1)(B). She has no right to trial by jury.
ORDER - 4
NOW THEREFORE IT IS HEREBY ORDERED:
Defendant’s Motion to Dismiss and to Strike (Dkt. 19) is GRANTED.
Plaintiff’s Second Cause of Action for Breach of Contract as set forth in the
Complaint is DISMISSED with prejudice, and Plaintiff’s jury trial demand is
STRICKEN from the Complaint.
ORDER - 5
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