Seventh Circuit Affirms Doctor Did Not Have Valid Assignment to Pursue ERISA Statutory Penalty Claim Against Plan Administrator

W.A. Griffin v. Seven Corners, Inc., No. 21-2332, 2021 WL 6102167 (7th Cir. Dec. 22, 2021) (Before: Kanne, Rovner, and Hamilton, Circuit Judges).

Plaintiff-Appellant W.A. Griffin is a dermatologist who sought to enforce a direct assignment of rights executed by one of her patients to pursue statutory penalties under ERISA against Defendant-Appellee Seven Corners, Inc. Dr. Griffin alleged that Seven Corners failed to provide her with certain plan documents before she filed suit seeking payment for unpaid medical services she provided to the patient. The ERISA plan at issue required that Seven Corners consent to the assignment of rights for it to be valid. The district court found that there had not been a valid assignment of Dr. Griffin’s patient’s rights because the defendant did not consent to the assignment.

On appeal, the Seventh Circuit agreed with the district court that Dr. Griffin did not have standing to sue for statutory penalties since she was not a participant or beneficiary of the ERISA plan and had not obtained Seven Corners’ consent to the assignment of rights. The court explained that courts must enforce the terms of an ERISA plan strictly. The plan at issue is unambiguous that its benefits and rights may not be assigned without the defendant’s consent and Dr. Griffin did not obtain that consent. Since she is not a valid assignee or beneficiary under the plan’s terms, she cannot collect a statutory penalty. The court affirmed summary judgment for the defendant.