Your reliable source for summaries of recent ERISA decisions
Below is Roberts Disability Law’s summary of this past week’s notable ERISA decisions.
In Hancock v. Illinois Cent. Sweeping LLC, No. 13 C 857, __F.Supp.3d___, 2014 WL 5822627 (N.D. Ill. Nov. 10, 2014), the trustees of a multiemployer health and welfare fund covering the unionized workers of Illinois Central Sweeping LLC (“ICS”), a street sweeping company, brought suit against ICS seeking payment for allegedly delinquent contributions between October 2006 and December 2011, plus interest, liquidated damages, attorney fees, and various other sums. ICS counterclaimed, seeking recompense for alleged overpayments that it made in the same timeframe. Plaintiffs moved for summary judgment on ICS’s counterclaims and for partial summary judgment on their claims. The court granted summary judgment as to the 158 weeks’ uncontested liability for underpayments (63 to the Welfare Fund, 95 to the Pension Fund); the unpaid interest, and 10% liquidated damages on the undisputed late payments; and the auditor fees. But, the court denied summary judgment as to all of Plaintiffs’ other underpayment claims and both of ICS’s counterclaims.
ICS argued that it owes no contributions to the Pension Fund for weeks in which the employee worked less than two full days. In denying the trustees’ motion on this claim, the court found that on the summary judgment record, a reasonable factfinder could conclude that the conduct of Plaintiffs and their auditor was misleading and that ICS’s detrimental reliance on that conduct in making benefit payments was reasonable, and thereby find for ICS on its estoppel defense. With respect to the claim for liquidated damages on the delinquent contributions paid before suit was filed, the trust agreements provide that the purpose of the liquidated damages provision is “to compensate the Trust Fund for the additional administrative costs and burdens imposed by delinquency or untimely payment of contributions,” and that the higher 20% rate kicks in “should there be further delay in payment that necessitates the filing of a lawsuit.” Arguably, ICS’s failure to pay interest or penalties (at the 10% rate) on the delinquent contributions before a suit is filed would be an initial delay in payment, not a further delay. A reasonable factfinder could conclude that the only payments that are delayed (from their original due date to the audit date), and then further delayed (from the audit to the lawsuit), are the contributions themselves. As such, the court denied summary judgment as to whether the 20% liquidated damages rate applies to the tardy payments in 2010 and 2011 and determined that whether Plaintiffs can recover additional liquidated damages must await trial.
With respect to the counterclaims, ICS rested its restitution claim on a theory of unjust enrichment. The court rejected Plaintiffs’ argument that the Pension Fund could not have been unjustly enriched by ICS’s overpayments because the fund entered those mistaken contributions into its participant tracking computer database and determined the participant’s pension credits based on the contribution weeks entered into the Database. The court explained that whether Plaintiffs have been unjustly enriched has nothing to do with its bookkeeping. “By Plaintiffs’ argument, every litigant (not just in ERISA cases) could avoid a finding of unjust enrichment simply by entering ill-gotten gains into a spreadsheet. That cannot possibly be the law.” The court denied Plaintiffs summary judgment on this counterclaim and advised that ICS will have the burden at trial of proving that Plaintiffs were unjustly enriched. The court also reserved for trial the issue of whether ICS paid too high a contribution rate to the Welfare Fund and, if so, whether Plaintiffs were unjustly enriched by the overpayments.
Rental Properties Do Not constitute a “trade or business” under the controlled group theory as defined by 29 U.S.C. § 1301(b)(1). In Auto. Indus. Pension Trust Fund v. Tractor Equip. Sales, Inc., No. 13-CV-03703-WHO, __F.Supp.3d___, 2014 WL 5810336 (N.D. Cal. Nov. 7, 2014), the court considered whether a fund may enforce the withdrawal liability against three rental properties because they constitute a “trade or business” under the controlled group theory as defined by 29 U.S.C. § 1301(b)(1). Defendants Steven and Rena Van Tuyl owned three residential properties that they leased to third parties. They also owned a controlling interest in Defendant Tractor Equipment Sales, Inc. (“TES”), which participated in Plaintiff Automotive Industries Pension Trust Fund, a multiemployer pension plan as defined under 29 U.S.C. § 1002(37)(A). TES withdrew from the Fund in 2010, triggering withdrawal liability that remained unpaid. Applying the basic framework in Bd. of Trustees of W. Conference of Teamsters Pension Trust Fund v. Lafrenz, 837 F.2d 892 (9th Cir.1988) and Carpenters Pension Trust Fund for N. California v. Lindquist, No. 10-03386-SC, 2011 WL 2884850 (N.D. Cal. July 19, 2011), aff’d, 491 Fed.Appx. 830 (9th Cir. 2012) for making section 1301(b)(1) determinations, the court found that the Van Tuyls’ leasing activities do not rise to the level of a trade or business within the meaning of section 1301(b)(1). Congress’s purpose in enacting section 1301(b)(1) is to prevent the controlling group from avoiding withdrawal liability by shifting corporate assets into other business ventures under its control. Property leases between two commonly-controlled entities constitute a trade or business but the mere ownership of property, without more, is insufficient to trigger controlled group liability under section 1301(b). Applying this framework to the instant case, the court found that a factfinder could not reasonably conclude that the Van Tuyls’ leasing activities rise to the level of a trade or business under section 1301(b)(1). Throughout the period of TES’s participation in the Fund, two of the three properties were leased to a single, continuous tenant, while the other property was either used as the Van Tuyls’ own vacation home or was leased to friends and family. The Van Tuyls spent minimal time maintaining or managing the properties except to deposit the rent they received, they considered two of the properties to be passive property holdings, and their leasing of the third property to be a charitable donation. Although an “economic relationship” is not required, the court found that there is no evidence of any economic relationship between any of the three properties and TES. Further, the court could find no case in which leasing activities as limited as the Van Tuyls’ were found to have constituted a trade or business under section 1301(b)(1) where there was no economic relationship between the leased property and the withdrawing employer. The court also found that the Van Tuyls did not waive their right to contest the issue of controlled group liability by failing to initiate arbitration. While the Ninth Circuit has not yet directly addressed the issue, several other circuit courts have held that the issue of whether a defendant is an employer within the meaning of section 1301(b)(1) is a matter for the court to decide, not the arbitrator.
Assignee of a Participant Is a “Beneficiary” under ERISA and an ERISA Obligation may not be Discharged, in the Presence of a Valid Assignment, by Paying the Participant. In Metcalf v. Blue Cross Blue Shield of Michigan, No. 3:14-CV-00302-ST, __F.Supp.3d___, 2014 WL 5776160 (D. Or. Nov. 5, 2014), the plaintiff is a chiropractor who regularly treats individual participants enrolled in Defendant Daimler Trucks North America LLC Group Health Plan (“Plan”). Healthcare providers who participate in the Plan are paid directly by the Plan; non-participating providers are typically paid by their patients, who must then file a claim with the Plan for reimbursement. Rather than participate in the Plan, the plaintiff has his patients assign their right to reimbursement directly to him and authorize him to pursue their claims on their behalf, as well as any other rights they have under the Plan in connection with his services. Under this arrangement, the plaintiff’s patients get treated without having to pay out of pocket, and the plaintiff streamlines his cash flow. The plaintiff brought suit against Blue Cross and the Plan for failing to pay him directly for the services, where Blue Cross issued the payments directly to plaintiff’s patients. The court noted that ERISA is silent as to whether healthcare benefits may be assigned and the consensus among the federal courts is that ERISA neither mandates nor prohibits the assignability of healthcare benefits. Further, the Plan at issue in this case does not contain an anti-assignment clause so the assignments to the plaintiff are valid. The plaintiff asserted four claims for relief, two of which are at issue here: a claim under 29 U.S.C. § 1132(a)(1)(B), for denying claims for benefits; and second, a claim under § 1132(a)(3), for failing to conduct a full and fair review of his claims. The defendants argued that the plaintiff failed to state a claim for relief because he is not a statutory “beneficiary,” has standing only derivative of his assignors, and has no right upon which to sue. The one basic factual premise of the defendants’ argument is that they have already paid all benefits owed-not to the plaintiff, but to the participants, his patients. The court determined that regardless of the merits of the defendants’ argument, several parts of the plaintiff’s claims survive. As a matter of statutory interpretation, the assignee of a participant is a “beneficiary” under ERISA with an independent cause of action. Finally, under federal common law, an ERISA obligation may not be discharged, in the presence of a valid assignment, by paying the participant-assignor rather than the assignee. The court did dismiss the plaintiff’s third alternative claim that if he cannot pursue claims for benefits as an assignee of his patients, then Blue Cross has breached its implied contract to pay him as a per-claim participating provider. However, the court found that there is no contract or agreement between the plaintiff and the Plan because the plaintiff agreed to participate on a per-claim basis was with his patients, not with defendants. Thus, any claim based on defendants’ failure to pay the plaintiff on a per-claim basis must be pursued by him under ERISA as an assignee of the Plan participants.
Disability Benefit Claims
Nemeth v. Andersen Corp. Welfare Plan, No. 14-CV-270-JDP, 2014 WL 5802020 (W.D. Wis. Nov. 7, 2014) (in dispute involving Hartford’s denial of Plaintiff’s application for long term disability benefits and Plaintiff’s request for money damages in the amount of the benefits owed, plus attorney fees and costs, and declaratory and injunctive relief to order Hartford to pay the benefits owed, granting Hartford’s motion to dismiss any claim for equitable relief under 29 U.S.C. § 1132(a)(3), but rejecting Hartford’s argument that if plaintiff has any remedy under § 1132(a)(1)(B), then she has no remedy under § 1132(a)(3); and denying Hartford’s motions for protective order from discovery and for leave to file an amended pleading asserting that Plaintiff has waived her claim).
Zisk v. Gannett Company Income Prot. Plan, No. 14-CV-00391-YGR, 2014 WL 5794652 (N.D. Cal. Nov. 6, 2014) (in action seeking to recover long term disability benefits pursuant to § 1132(a)(1)(B) and equitable relief in the form of an equitable surcharge against Defendant Life Insurance Company of North America (“LINA”) on account of LINA’s alleged breach of fiduciary duty and mishandling of his claim pursuant to § 1132(a)(3), denying Defendant’s Motion to Dismiss the § 1132(a)(3) claim, and finding that: 1) the controlling authorities do not support dismissal as a matter of law of a claim under § 1132(a)(3) for individual relief on account of a breach of fiduciary duties by a claims administrator such as LINA; 2) the claim under § 1132(a)(3) seeks remedies against LINA only and are distinct from the unpaid benefits alleged in connection with Plaintiff’s claim against the Plan under § 1132(a)(1)(B)); and 3) the allegations of harm as a consequence of breaches of fiduciary duty by LINA are not duplicative of Plaintiff’s first claim against the Plan).
Schultz v. PNC Fin. Servs. Grp., Inc. & Affiliates Long Term Disability Plan, No. CIV.A. 13-156-DLB, 2014 WL 5796721 (E.D. Ky. Nov. 6, 2014) (finding that Liberty Life’s denial of Plaintiff’s LTD benefits was arbitrary and capricious where Liberty Life failed to follow ERISA’s regulations requiring it to consult a health care professional who was not involved in the adverse benefit determination when considering Plaintiff’s administrative appeal; remanding claim to Liberty Life with instructions to conduct a full and fair review since the Court “cannot conclude that Schultz is clearly entitled to benefits at this juncture.”).
Boyd v. Sysco Corp., No. 4:13-CV-00599-RBH, 2014 WL 5822785 (D.S.C. Nov. 10, 2014) (granting Plaintiff’s Motion to Compel Defendant to respond completely to Plaintiff’s interrogatory and specifically include person(s) involved in compiling the administrative record during the claims phase, pertinent dates of the compilation of the administrative record during the claims phase, reason(s) Defendants failed to respond to the request on November 19, 2012, and other pertinent details of the compilation process during the claims phase; denying Plaintiff’s motion to have Plaintiffs’ Requests to Admit deemed admitted, where Defendants finalized their investigation and amended their responses to Plaintiffs’ Requests eight days after their deadline and the eight-day delay in finalizing their investigation will not prejudice Plaintiffs in this action).
Bailey v. United of Omaha Life Ins. Co., No. 13-CV-02996 SHL, 2014 WL 5822846 (W.D. Tenn. Nov. 10, 2014) (finding that Plaintiff’s Complaint contains no allegation that United of Omaha acted improperly based upon its financial conflict of interest and Plaintiff is not automatically entitled to even limited discovery based solely upon the insurer’s inherent conflict of interest; denying Plaintiff’s motion to compel responses to eight discovery requests pertaining to two doctors who reviewed Plaintiff’s claim on United of Omaha’s behalf-Dr. Vicki Kalen and Dr. Joe Ordia).
Healy v. Fortis Benefits Ins. Co., No. 14-CV-00832-RS (MEJ), 2014 WL 5768537 (N.D. Cal. Nov. 5, 2014) (in matter involving de novo review of long term disability benefit denial, granting Plaintiff’s request for discovery seeking guidelines, procedures, or rules that were applied to Plaintiff’s claim but denying all other discovery requests, including: 1) communications between the parties regarding Plaintiff’s claim; 2) information about five medical reviewers that is probative of bias; and 3) depositions of medical reviewers).
Wright v. Louisiana Corrugated Products, LLC, No. CIV.A. 14-0744, 2014 WL 5803073 (W.D. La. Nov. 7, 2014) (in matter involving denial of payment for surgery under group health care policy, finding: 1) Plaintiff’s state law claim for failure to pay benefits under the plan is completely preempted and recast as a claim under ERISA § 502(a)(1)(B); 2) because Plaintiff failed to exhaust administrative remedies before filing suit, his converted claim under ERISA § 502(a)(1)(B) is premature and dismissed without prejudice; and 3) Plaintiff’s remaining state law claims for recovery of penalties and fees under § 22:1821 and for detrimental reliance damages under Louisiana Civil Code Article 1967 are conflict-preempted by ERISA, and dismissed with prejudice).
Breland v. Liberty Life Assur. Co. of Boston, No. CIV.A. 14-352, 2014 WL 5795681 (W.D. Pa. Nov. 6, 2014) (denying Plaintiff’s Motion to Remand to state court and granting Defendant’s Motion to Dismiss Plaintiff’s assumpsit, breach of fiduciary obligation, and violation of the Pennsylvania Unfair Trade Practices and Consumer Protection Law (“UTPCPL”) claims, finding that Plaintiff’s lawsuit for the recovery of long term disability benefits pre-empted any state law claims and that the UTPCPL was not a law specifically directed toward the insurance industry, and therefore does not fall under the “savings clause” exception).
Life Insurance & AD&D Benefit Claims
In re Shafer, No. 2:13-CV-00405-JMS, 2014 WL 5599064 (S.D. Ind. Nov. 4, 2014) (in interpleader action filed by MetLife for payment of life benefits, finding that the decedent disabled by Alzheimer’s Disease and Parkinson’s Disease was fully competent to execute a Power of Attorney giving his daughter the power to change beneficiaries to any insurance policies he owns; an Indiana law giving decedent’s daughter the burden of rebutting the presumption of undue influence by clear and unequivocal evidence since she used the Power of Attorney to change the beneficiary to herself is preempted by ERISA because Indiana common law would affect the Court’s determination of whether the beneficiary designation was valid, and, thus, “relates to” an ERISA plan; and the Power of Attorney was valid and properly used to change the Plan beneficiary from decedent’s ex-wife to his daughter, who is entitled to the life insurance benefits).
Medical Benefit Claims
Gates v. United Healthcare Ins. Co., No. 11-CV-3487 (KBF), 2014 WL 5800573 (S.D.N.Y. Nov. 7, 2014) (in putative class action involving a dispute of UHIC’s calculation of benefits and claims procedures under the United Healthcare Choice Plus Copay Plan, finding that: (1) the Calculation of Benefit methodology is unambiguous; (2) that injunctive relief is not available for past violations under § 502(a)(1) or § 502(a)(3) – for either benefits determinations or claims procedures; (3) while Plaintiff might be able to state a claim against a plan sponsor for co-fiduciary liability, the only relief sought for such violation is injunctive relief, which is unavailable to Plaintiff or otherwise procedurally nonsensical).
Bay Area Roofers Health & Welfare Trust v. Sun Life Assurance Co. of Canada, No. 13-CV-04192-BLF, 2014 WL 5795042 (N.D. Cal. Nov. 6, 2014) (in dispute between multiemployer Taft-Hartley Trust and stop-loss insurer, where insurer declined to pay for medical services of the dependents of an employee who provided a false Social Security number to obtain employment, granting summary judgment to insurer on Plaintiff’s ERISA § 502(a)(3)(B)(ii) claim seeking a declaratory judgment that Defendant possesses no power to determine eligibility for benefits for Plan participants, that the Plan administrator properly exercised its discretion to determine that Participant X was eligible to receive benefits under the Plan, and that all expenses paid on behalf of Participant X’s dependents were properly paid expenses of the Plan, because Plaintiffs’ request would amount to the Court issuing an advisory opinion where no case or controversy exists; Plaintiffs have not shown any injury under ERISA that is traceable to Defendant’s actions in denying reimbursement under the stop-loss policy).
Vangas v. Montefiore Med. Ctr., No. 11 CIV. 6722 ER, 2014 WL 5786720 (S.D.N.Y. Nov. 5, 2014) (in matter alleging failure to properly notify of right to continue coverage under medical plan in violation of 29 U.S.C. § 1166(a)(4)(A), finding that although the notification letter generated for Plaintiffs was improperly addressed because it did not use the only “acceptable” abbreviation for Cornwall on Hudson, Defendant demonstrated that it fulfilled its good faith obligation by following its standard operating procedures for the mailing of COBRA notification letters and that Defendant used means reasonably calculated to reach Plaintiffs, particularly because Plaintiffs received 18 other pieces of incorrectly addressed mail).
Pleading Issues & Procedure
Marciniszyn v. Cigna Corp., No. 3:14-CV-00642 JAM, 2014 WL 5824967 (D. Conn. Nov. 11, 2014) (where pro se Plaintiff served Defendant Cigna Corporation with a Connecticut Superior Court Small Claims Writ and Notice of Suit but had not yet returned the Writ to court, finding that action was not properly removed to federal court because it was never “brought in a State court” in the first place, but dismissing case outright for lack of federal jurisdiction).
Osberg v. Foot Locker, Inc., No. 07-CV-1358 (KBF), 2014 WL 5800501 (S.D.N.Y. Nov. 7, 2014) (in reconsidering previous decision to certify class, finding that Plaintiff’s request for plan reformation, based on allegation that Defendant made false and material misstatements and omissions in its adoption of a pension plan amendment in violation of ERISA § 102(a) and § 404(a), does not require detrimental reliance, but if reliance is required, class certification on the facts of this case is entirely supportable as reliance can be demonstrated on a generalized basis; and certifying the following class: All persons who were participants in the Foot Locker Retirement Plan as of December 31, 1995, who had at least one Hour of Service on or after January 1, 1996 (as defined under the Plan), and who were either paid a benefit from the Plan after December 31, 1995, or are still entitled to a benefit from the Plan; and the beneficiaries and estates of such persons and alternate payees under a Qualified Domestic Relations Order).
Shumpert v. Gen. Motors Life & Disability Benefits Program for Hourly Employees, No. 2:12-CV-14786, 2014 WL 5817009 (E.D. Mich. Nov. 10, 2014) (where disability claimant signed a Reimbursement Agreement prior to receiving Social Security Disability Insurance benefits and subsequently received SSDI benefits which retroactively offset disability benefits paid by the Plan, granting Defendant’s motion for repayment of benefits in the amount of $30,325.14 whether or not Plaintiff is still in possession of the funds).
Unum Life Ins. Co. of Am. v. Wilson, No. ELH-14-1585, 2014 WL 5797712 (D. Md. Nov. 6, 2014) (granting Unum’s Motion for Entry of Default Judgment against Defendant for failing to reimburse Unum an amount in long term disability benefits it overpaid as a result of Defendant’s receipt of SSDI and pension benefits, where Defendant signed a Disability Payment Options/Reimbursement Agreement as a participant in a group long term disability plan offered by her employer and the plan offsets other income benefits received by a claimant).
Withdrawal Liability & Unpaid Benefit Contributions
Einhorn v. DiMedio Lime Co., No. CIV. 13-3634 RBK/JS, 2014 WL 5816695 (D.N.J. Nov. 10, 2014) (granting judgment in favor of the Plaintiff in the amount of $1,087,026.23, the full withdrawal liability owed as determined by the Fund, and awarding interest due, liquidated damages, and attorney’s fees and costs incurred by Plaintiff in conjunction with this litigation).
Midwest Operating Engineers Welfare Fund v. Cnty. of Mercer, No. 14-2436, 2014 WL 5821795 (N.D. Ill. Nov. 10, 2014) (in matter where employee welfare benefit plan brought suit against Defendants seeking delinquent payments on behalf of two bargaining unit employees under two collective bargaining agreements, finding that the CBAs have lapsed and the Court does not have subject matter jurisdiction to hear this claim and granting motion to dismiss).
Mackey v. Sterling Sys. Inc., No. 14-CV-02040 MJD/TNL, 2014 WL 5810334 (D. Minn. Nov. 7, 2014) (granting Plaintiff’s Motion for Entry of a Default Money Judgment, finding that Sterling Systems and Jones are in default and the Funds are entitled to entry of judgment, Sterling Systems is liable to the Funds in the amount of $14,783.49 for unpaid contributions and liquidated damages for the months of April 2014 through June 2014, Jones is liable to the Funds in the amount of $15.24 for unpaid contributions and liquidated damages for the months of April 2014 through June 2014, and Sterling Systems and Jones are jointly and severally liable to the Funds in the amount of $2,017.66 for attorneys’ fees and costs).
Bd. of Trustees of Carpenters Fringe Ben. Funds of Illinois ex rel. Ambrose v. Southside Concrete, Inc., No. C13-1016, 2014 WL 5791558 (N.D. Iowa Nov. 6, 2014) (in matter seeking unpaid fringe benefit contributions where non-party Custom Concrete Designs, Inc. entered into a CBA that required it to pay monthly fringe benefit contributions to the Funds; where Custom was solely owned by Scott McAtee and his wife, Jeni McAtee, and was in the business of concrete construction; where Defendant Southside Concrete, Inc. was later incorporated and is solely owned by Scott McAtee and Jeni McAtee, and is also engaged in the business of concrete construction; finding that Southside is the alter ego of Custom and is liable for contributions, payment of interest, costs and attorneys’ fees, owed by Custom to the Funds).
Bd. of Trustees of the Laborers Health & Welfare Trust Fund for N. California v. Montes Bros. Constr., No. C-14-1324 EMC, 2014 WL 5768580, at *1-2 (N.D. Cal. Nov. 5, 2014) (granting Plaintiffs’ Motion for Default Judgment and ordering: (1) a monetary judgment in the amount of $44,978.43 for delinquent trust fund contributions, liquidated damages, and interest, (2) an award of reasonable attorney’s fees in the amount of $3,442.50 for 11.75 hours on this case at the rates charged by the attorneys and paralegals ($345 per hour for two attorneys, $290 per hour for the other two attorneys, and $145 per hour for the two paralegals), (3) an order directing Defendant to submit to an audit of their books and records, and (4) an order enjoining Defendant to timely submit all required monthly contributions and contribution reports in accordance with the Agreements).
Bd. of Trustees of Laborers Health & Welfare Trust Fund for N. California v. Torres, No. C-12-02633 DMR, 2014 WL 5692462 (N.D. Cal. Nov. 4, 2014) (recommending grant of motion for default judgment against Defendant Rene Amilcar Torres, an individual dba Vector Engineering Contractors Inc., for unpaid employee fringe benefit contributions and related interest and liquidated damages, and attorneys’ fees and costs, finding that under the Eitelfactors: 1) Plaintiffs will suffer great prejudice if the court does not enter a default judgment because Plaintiffs are otherwise likely to be “without other recourse for recovery;” 2) the SAC sufficiently pleads the elements of a violation of 29 U.S.C. § 11452 by alleging that Defendant is an employer obligated under the collective bargaining agreement to make contributions to the Trust Funds but failed to do so in accordance with the terms of that agreement; 3) Plaintiffs are likely to prevail on the merits of the Section 1145 claim; 4) the total sum of actual and statutory damages, interest, attorneys’ fees, and costs that Plaintiffs seek to recover is supported by the evidence, tailored to Defendant’s alleged misconduct, and properly calculated; and 5) Defendant has not appeared in this action, nor contested any of Plaintiffs’ material facts, and there is nothing that suggests Defendant defaulted due to excusable neglect).
* Please note that these are only case summaries of decisions as they are reported and do not constitute legal advice. These summaries are not updated to note any subsequent change in status, including whether a decision is reconsidered or vacated. The cases reported above were handled by other law firms but if you have questions about how the developing law impacts your ERISA benefit claim, the attorneys at Roberts Disability Law may be able to advise you so please contact us. Case summaries authored by Michelle L. Roberts, Partner, Roberts Disability Law, 1050 Marina Village Parkway, Ste. 105 Alameda, CA 94501; Tel: 510-230-2090.
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