Failure to Challenge all Bases for a District Court’s Decision in the Court of Appeals Results in Affirmation

A recent decision out of the Sixth Circuit Court of Appeals is a good reminder of the importance of filing a comprehensive appeal if you are challening a district court’s determination in an ERISA case (or any case for that matter). In Stewart v. IHT Ins. Agency Grp., LLC, No. 20-3754, __F.3d__, 2021 WL 834001 (6th Cir. Mar. 5, 2021), the Sixth Circuit affirmed a district court’s judgment on the bases that the Plaintiff-Appellant did not challenge both grounds upon which the decision was based.

Plaintiff-Appellant Merrilee Stewart released all claims “from the beginning of the world” to the present against Defendant via arbitration proceedings which were affirmed by a state court. Then she and her son sued Defendant alleging violation of ERISA when it revoked Stewart’s health and life insurance benefits.

“The district court dismissed the complaint with prejudice on two alternative grounds: (1) Stewart had released all her claims against the defendants, and (2) res judicata barred her from relitigating her removal from RRL and discontinued benefits.” On appeal, the Stewarts only challenged the first ground. The court affirmed the judgment because the Stewarts needed to win two arguments and they only raised one. “It does no good for a track-and-field hurdler to clear just the first hurdle in a race and then sit down on the track.”