Legal Case Analysis
Case Analysis A
Black & Decker Disability Plan v. Nord
Statement of Facts
This is a case between an employee welfare benefit plan provider and a disabled employee of a given company. The said employee welfare benefit plan was governed by the Employee Retirement Income Security Act of 1974 or otherwise known as ERISA and gives benefits for qualified disabled employees of Black and Decker Corporation and its subsidiaries. There were times when the said plan provider had passed on authority to the Metropolitan Insurance Company or MetLife in rendering primary recommendations on benefit claims.
In connection with that, Nord who is the respondent of this case and an employee of Black and Decker Company’s subsidiary submitted a certain claim for disability benefits on the strength of the plan. However, MetLife denied such submission of claim. There was a review conducted by MetLife prior to the denial of the application for claim of benefits. What Nord did was that he submitted papers as evidences of the examination from his doctor named Dr. Hartman as well as the documents of an orthopedist for that matter.
The statement of these treating physicians is that Nord is unable to work due to suffering from a degenerative disc disease and chronic pain. In order to obtain an independent examination, the company involved referred Nord to another physician. However, the physician had given an opposite recommendation on the condition of Nord and stated that Nord can perform sedentary jobs as he can be aided by proper medication. As a result, MetLife provided a final recommendation thereby denying the benefit claim of Nord which was accepted outright by Black and Decker Company.
Nord’s purpose to question that recommendation led him to file a case before ERISA. The District Court decided in favor of the employee benefit plan provider citing that it can never be considered abuse of discretion on the part of Black and Decker Disability Plan. And yet, the Ninth Circuit decided in favor of Nord giving in his favor a summary judgment.
The decision of the Court of Appeals was explained in such a way that when doing a benefit determinations, plan administrators of ERISA must follow the “treating physician rule”. In the given rule, there is requirement on the part of the plan administrator who reject’s findings of treating physicians to explain such rejection supported by substantial evidences. As such, there was a failure on the part of the plan administrator to submit such explanation or justification in lieu of its rejection of the treating physicians’ recommendation.
Legal and Ethical Issues Statement
The legal issue of the case is that: is it legal for the court a quo to decide that the administrator of an ERISA-covered disability plan must follow a treating physician rule in determining a participant’s disability, so that the administrator is mandated to admit an opinion of a treating physician on disability unless the administrator rebuts that opinion in writing based upon substantial evidence in the record. For the ethical issue on this case: is it ethical for courts of justice to make the interpretation of the law complicated in favor of the disability benefit provider and against Nord who is a disabled employee? Is it right to deny a disabled employee’s claim in exchange of the will to bow down before a rule that is strictly implemented against the rights of disabled employees? The answers to these questions demand a thorough understanding and scrutiny of the case touching the mandate of the Department of Labor to protect the rights of those who composed labor force of the country.
Applicable Legal Rules
The sole legal basis of the case decision is found on Section 502 paragraph A under number 1 paragraph B of Employee Retirement Income Security Act of 1974 which provided every disabled employee the right to demand or recover benefits under employee welfare benefit plan.
Support for Ethical Issues
We simply points out to the correctness of any decision of any court of justice based on ethical principles that we are consciously aware of if we speak of ethical issues. The failure of the benefit plan administrator to accept and give credence to the recommendation or reports given by the treating physicians of Nord is an actual example of unethical practice. There is nothing wrong if Nord could provide supporting documents for his claims of benefits such that it was done by him to provide evidences.
Besides, it is supposed to be the role of the administrator to double check on the credibility of the said supporting papers submitted by Nord as it carries with it interests that affect his living. What is the purpose of the law by which ERISA was created when the primary purpose to protect disabled employees could not be served? There is none and Nord could do nothing but to assert his rights up to the highest court of the land. The case at bar is just a matter of justice and equity blended with the capability to apply the law under justice and fair play. Hence, the primary concern of the court is to serve the quest of any disabled employee as long as credible proofs can be presented by him for any claim of benefits.
The Court of Appeals decided the case in favor of the respondent named Nord. The conclusion of the Court of Appeals is that the only proof in contrast to the claim of the respondent on disability is the opinion of Dr. Mitri which could not reasonably overcome all the other evidence that it considered as proving disability. As such, the view of the Court of Appeals demands payment in favor of Nord for he is indeed entitled to benefits based on the benefit plan for his disability of 30 months duration. The decision of the Court of Appeals could be right but there are technical and legal matters that the Supreme Court must weight down in order to come up a more reasonable decision.
One of these legal and technical bases in deciding the case is on the negative requirement on ERISA and regulations of the Secretary of Labor mandating any plan administrator to provide particular weight to the opinions of treating physician in cases of benefits claim. What the regulations and ERISA requires is to establish a full and fair view on all benefits claim involving plan administrators for that matter.
It should be remembered that the law provides wide discretion on the part of plan administrators to weigh evidences in cases involving claim of disability benefits. In connection with these, the applicability of the treating physician rule which has been the main issue in this case is not also applicable under the Social Security System on its disability program. Whatever may be the administering body on benefits claim, the treating physician rule must be applied with uniformity so that justice and fair play will prevail.
The erroneous analysis of the Ninth Circuit regarding the applicability of the treating physician rule did not really passed on the scrutiny of the Supreme Court. As such, the highest court of the land decided that a treating physician rule is not appropriate and not necessary under ERISA (Cornell: Black and Decker Disability Plan v. Nord). The main ethical consideration in this case is that the rules and regulations provided in ERISA do not only protect the disabled employees but also benefit administrators. For future actions against employees concerning claim of disability benefits, ERISA will remain a comprehensive guide in doing so.
Case Analysis B
IBP, Inc. v. Gabriel Alvarez, Abdela Tum, et al. v. Barber Foods, Inc., dba Barber Foods
Statement of Facts
There are various persons involved in this case since it also happened in the workplace. This is a consolidation of two cases before the Supreme Court. The respondents are some workers of the IBP Company and the petitioner is the representatives of IBP Company. Petitioner IBP company is a huge company that produces fresh beef, pork, and similar production. Its plant is located in Pasco, Washington. Its employees reaches a number for about 178 employees in 113 job classifications pertaining the slaughter division and 800 line employees in 145 work classification assigned in the processing division.
There is a requirement for all the employees that they should store their protective gears and equipments within the company locker rooms. These protective equipments and gears include outer garments, hard caps, hairnets, headset, hand gloves, aprons, and many other protection for the body especially those who uses knife at work. In the area wherein the locker rooms are found, most of the employees don their protective gears and outfit there. The case erupted when the pay of the production workers was affected by the time they spent in donning the aforementioned protective gears.
Essentially, the pay of the workers is based on the time they spent in making cuts of meats and putting it in bags. Since the year 1998, it was the policy of the company to pay for the 4 minutes time spent for every employee in changing clothes. So then, the year after, employees of the said company who are the respondents of this case filed a suit against the former praying for compensation for pre-production activities as well as post production work. These duration of time represents the time used by employees in wearing the protective gears and as well as changing clothes after their respective work shifts.
The lower court decided the case in favor of the respondents stating that wearing of protective gear before work proper were compensable under the Fair Labor Standards Act of 1938 (FLSA) since they were integral and indispensable to the job of the respondents who need to wear those outfit. In addition to the said ruling, the time spent by the employees in walking time between the area of the locker room and the production floor was also compensable since it happened during working days (Findlaw: IBP, Inc. v. Alvarez et. al). The District Court also decided on the same tract stating that those who are using knives in the workplace must be given compensation for walking time and preproduction and post production work. The decisions of the said lower courts are obviously in favor of the respondents.
In addition to that, the Court of Appeals also decided in favor of the respondents only that it gives different reasons. It uses the de minimis theory as a matter of law in trying to explain why donning special protective gear is compensable under the laws. Hence, this certiorari was filed against the employees involved in the case.
Legal and Ethical Issues Statements
Is it legal for the lower courts to decide that preproduction and post production activities of the employees as well as time spent for walking from the locker room to the work areas are compensable under the laws? Is it ethical for the IBP, Incorporated to disregard the preproduction and post production activities of the employees as well as time spent for walking from the locker room to the work areas for compensation accounting? The legal and ethical issues in this case rest primarily on the willingness of the company to abide by the universal tenet that the workforce is the backbone of the economy such that it should be protected by the laws. The Supreme Court, in its legitimate power to grant the respondents their requests and prayers for compensation they deserve is an example of giving spirit to the laws.
Applicable Legal Rules
The policy adopted by the Secretary of Labor in 1947 sustains the views of the respondent that when donning and doffing of shielding gear are compensable actions, they may also classify the external restrictions of the workday (Findlaw: IBP, Inc. v. Alvarez et. al). When speaking about the workday we may think of work proper and preparation for work. Basically, what has been asked by the respondents was the compensation that they deserve for the time spent for activities that are indispensable to the nature of their job.
Under those rules, the little minutes used up in walking between the locker rooms and the production area are parallel to the time spent in walking amid two different workplaces on the disassembly line (Findlaw: IBP, Inc. v. Alvarez et. al). The provisions of the law found in §790.7(g), n. 49 which states that post donning walking time is not “necessarily” disqualified from §4(a)(1)’s scope, does not mean that such time is always excluded and is inadequate to defeat apparent statements in the policy’s text that support the holding of the case. Based on this provision, it is but proper to scrutinize the issues presented for the benefit of the employees.
Moreover, the Portal-to-Portal Act states that employers would not sustain liability on account of their failure to compensate minimum wages or overtime compensation for any action that was not compensable by either an express contract or a recognized custom or practice. This rule was explained by the highest court of the land stressing that the issues be legitimately assessed to protect the rights of both sides. Hence, the time spent between walking from the locker room to the work area as well as pre-production and post production must be made compensable by IBP Company.
Support for Ethical Issues
The major decision of the Supreme Court which affirms that the time spent by respondents in walking between changing and production areas is compensable under the FLSA is an ethical thing to do. It obviously protects the rights of the employees while working for their respective employers. The law gives protection on the rights of workers which contributed much on economic development in the country. Basically, without the honesty and hard work of the workers in IBP plant, there will be no increase in the profits of the company that contributed much to the economic condition of the nation. It may be a natural reaction on the part of the company to withhold payment for the employees on the time they spent for non-actual work, it is however not a good practice for them to do against their employees.
This is a case that will give a big impact on working individuals as the decision truly live up to the purpose or intent of the law that is to protect the rights of workers. It is not persuasive for IBP Company to mention that walking time is not compensable. Its utter disregard on the rights of the employees was strongly opposed by the judiciary since it could be noticed that there was a unanimous decision of all Justices deciding on the case. In other words, there is no doubt that employees are entitled to their compensation when they spend walking time from the locker room to the work areas as well as pre production and post production activities. The two laws applied in this case are the Fair Labor Standards Act of 1938 (FLSA) and the Portal-to-Portal Act of 1947 which both protects the rights of the employees to equitable compensation.
In addition, the second most important issues in this case is whether or not the time employees use up for waiting to put on the protective gear is compensable under the statute. The law also supported the idea that this issue must be decided on the positive. Therefore, the time for waiting being used by employees in putting their protective is subject to compensation by the company. It should be made clear that although the Court of Appeals decided in favor of the respondents, it gives different rationale that made the case complicated when it is supposed to benefit the employees based on existing laws. Hence, the Supreme Court answered all the issues via certiorari grant for the resolution of the existing conflict in the court a quo.
Finally, the employers are entitled to identify the respective activities of employees based on the law that requires compensation. The time they spent in work is very much valuable that it needs to be paid even though it is not at all for the principal activities of the job. Since this case was decided unanimously by the Supreme Court, there is a presumption that future employment with similar nature would be safely guarded by the law. For overall emphasis, the judgment of the Court of Appeals for the Ninth Circuit was affirmed for the case No. 03-1238. The decision of the Court of Appeals in case No. 04-66 was affirmed and reversed in part by the Supreme Court. Thus, the consolidated case was remanded for further determination as required by judgment.
Cornell. (2008). Black and Decker Disability Plan v. Nord. Retrieved September 29, 2008, from www.law.cornell.edu/supct/html/02-469.ZS.html – 13k .
Findlaw. (2008). IBP, Inc v. Alvarez et. als. Retrieved September 29, 2008, from