In Amara v. Cigna Corp., No. 20-202, __F.4th__, 2022 WL 16842742 (2d Cir. Nov. 10, 2022), the Second Circuit considered consolidated appeals of several postjudgment orders brought by Plaintiffs-Appellants in this ERISA action where Cigna Corporation was ordered to reform its pension plan and pay a greater benefit to the plaintiff class. After the Second Circuit previously affirmed final judgment in this case, the district court issued four decisions resolving disputes between the parties about the methodology Cigna would use to calculate the reformed pension benefits. A year later, Plaintiffs moved for sanctions and other relief against Cigna, which the district court denied. The Plaintiffs appealed to the Second Circuit challenging the district court’s order denying sanctions as well as its earlier orders regarding methodology for calculating benefits. Cigna moved to dismiss the appeals, which the Second Circuit granted in part and denied in part. The court dismissed Plaintiffs’ appeal from the Methodology Orders due to untimeliness. It affirmed the Sanctions Order on the merits and affirmed the district court’s order denying Plaintiffs’ motion for an equitable accounting.
With respect to Plaintiffs’ appeal in No. 20-202 from the district court’s Methodology Orders and the Sanctions Order, the court agreed with Cigna that the appeal from the Methodology Orders is untimely because they became final more than 30 days before Plaintiffs appealed. As the court explained, “The district court issued the last Methodology Order in November 2017. And it resolved Plaintiffs’ request for attorney’s fees in November 2018. Because Plaintiffs did not appeal until January 2020, their appeal is untimely, and we lack jurisdiction.” However, the court does have jurisdiction over the Sanctions Order because it is a substantive post-judgment order and Plaintiffs timely filed an appeal of that order. In affirming the Sanctions Order on the merits, the court did not decide whether the Methodology Orders were correctly decided, but whether the district court properly interpreted the Methodology Orders in the Sanctions Order.
The court also concluded that the district court did not err in denying Plaintiffs’ motion for an equitable accounting, where the district court held that Plaintiffs’ request for a post-judgment equitable accounting was unwarranted because Cigna had provided acceptable explanations for the potential problems with its compliance. The district court previously accepted Cigna’s representations that it remitted the amounts owed to the class members. The court found that the district court made a factual finding that Cigna had adequately complied with the final judgment and that finding was not clearly erroneous.
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