Cavanagh v. Northern NE Benefit Trust

2013 DNH 035
CourtDistrict Court, D. New Hampshire
DecidedMarch 15, 2013
Docket12-cv-394-LM
StatusPublished

This text of 2013 DNH 035 (Cavanagh v. Northern NE Benefit Trust) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cavanagh v. Northern NE Benefit Trust, 2013 DNH 035 (D.N.H. 2013).

Opinion

Cavanagh v . Northern NE Benefit Trust 12-cv-394-LM 3/15/13

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Robert V . Cavanagh and Rhoda M . Cavanagh

v. Civil N o . 12-cv-394-LM Opinion N o . 2013 DNH 035 Northern New England Benefit Trust

O R D E R

In an action that has been removed from the New Hampshire

Superior Court, Robert and Rhoda Cavanagh have petitioned for a

declaratory judgment concerning the amount of the lien that may

be asserted by the administrator of Robert’s employee-benefit

plan against a recovery he received from a third-party

tortfeasor. Specifically, they seek to reimburse the plan

administrator, Northern New England Benefit Trust (“NNEBT”), in

an amount less than the total amount of benefits provided by

NNEBT under the plan. NNEBT has filed a counterclaim under 29

U.S.C. § 1132(a)(3) in which it asks the court to enforce an

equitable lien against Robert Cavanagh (“Cavanagh”)1 equal to the

full amount of the medical expenses it paid on his behalf plus

the full amount of the short-term disability benefits it paid

1 While NNEBT’s counterclaim seeks an order enforcing a lien against Cavanagh, the court recognizes that liens are placed against property (including sums of money), not property owners. him. Before the court are the Cavanaghs’ motion for partial

summary judgment and NNEBT’s motion for judgment on the

administrative record. Both motions are duly opposed and, for

the reasons that follow, both are denied.

Summary Judgment Standard

“Summary judgment is warranted where ‘there is no genuine

dispute as to any material fact and the movant is entitled to

judgment as a matter of law.’” McGair v . Am. Bankers Ins. C o .

of Fla., 693 F.3d 9 4 , 99 (1st Cir. 2012) (quoting Fed. R. Civ.

P. 56(a); citing Rosciti v . Ins. C o . of Penn., 659 F.3d 9 2 , 96

(1st Cir. 2011)).

Background

The facts in this section are drawn from the parties’ Joint

Statement of Material Facts (“Jt. Statement”), document n o . 1 3 ,

and the exhibits attached thereto.

In July of 2011, while Cavanagh was riding a motorcycle, he

was hit by a truck. At the time of the collision, Cavanagh was

employed by Anheuser-Busch, Inc., and he was a participant in an

Anheuser-Busch employee-benefit plan administered by NNEBT.

The plan document provides that the plan does not cover

“[e]xpenses incurred by a Participant to the extent any payment

is received for them either directly or indirectly from a third

2 party tortfeasor . . . .” J t . Statement, Ex. C (doc. n o . 1 3 - 3 ) .

Under the heading “Subrogation/Right of Reimbursement,” the plan

document states:

If a Participant incurs a Covered Expense for which, in the opinion of the plan or its claim administrator, another party may be responsible or for which the Participant may receive payment as described above:

1. Subrogation: The Plan shall, to the extent permitted by law, be subrogated to all rights, claims or interests that a Participant may have against such party and shall automatically have a lien upon the proceeds of any recovery by a Participant from such party to the extent of any benefits paid under the plan. A Participant or his/her representative shall execute such documents as may be required to secure the plan’s subrogation rights.

2. Right of Reimbursement: The plan is also granted a right of reimbursement from the proceeds of any recovery whether by settlement, judgment, or otherwise. This right of reimbursement is cumulative with and not exclusive of the subrogation right granted in paragraph 1 , but only to the extent of the benefits provided by the plan.

Id. Under the heading “Lien of the Plan,” the plan document

states:

By accepting benefits under this plan, a Participant:

• grants a lien and assigns to the plan an amount equal to the benefits paid under the plan against any recovery made by or on behalf of the Participant . . . ;

• agrees that this lien shall constitute a charge against the proceeds of any recovery and the plan shall be entitled to assert a security interest thereon;

3 • agrees to hold the proceeds of any recovery in trust for the benefit of the plan to the extent of any payment made by the plan.

Id. Finally, the plan document includes the following

miscellaneous terms relevant to the claims in this case:

• The plan’s right of recovery shall be a prior lien against any proceeds recovered by the Participant. This right of recovery shall not be defeated nor reduced by the application of any so-called “Made-Whole Doctrine” . . . or any other such doctrine purporting to defeat the plan’s recovery rights by allocating the proceeds exclusively to non-medical expense damages.

• No Participant hereunder shall incur any expenses on behalf of the plan in pursuit of the plan’s rights hereunder, specifically; no court costs, attorneys’ fees or other representatives’ fees may be deducted from the plan’s recovery without the prior express written consent of the plan. This right shall not be defeated by any so-called “Fund Doctrine”, “Common Fund Doctrine”, or “Attorney’s Fund Doctrine”.

Id.

Shortly after his accident, Cavanagh executed an agreement

with NNEBT under which NNEBT promised to pay his medical

expenses and to pay him weekly disability income benefits. That

agreement also included the following term:

[F]rom any monies received by way of any recovery, by judgment, settlement, compromise or otherwise, by or from any third party whose conduct is claimed to have caused the injury or illness [for which the participant has received benefits under the plan], Participant agrees to first reimburse the Trust to the extent of all payments made by the Trust hereunder without reduction for attorney’s fees or costs.

4 Participant agrees and understands that the Trust is to be reimbursed at 100% for all disbursements for weekly indemnity, medical, hospital, nursing and related expenses.

J t . Statement, Ex. A (doc. n o . 1 3 - 1 ) .

As a result of his accident, Cavanagh was totally disabled

from work for approximately four months. For that disability,

he received $7,831.05 in weekly benefits from NNEBT. In

addition, NNEBT paid $39,118.40 in medical bills on Cavanagh’s

behalf. Cavanagh has received $200,000 from two insurance

policies covering the driver who struck him, and he is

continuing to pursue a recovery of $50,000 from his own

underinsured motorist coverage.

In the petition for declaratory judgment they brought

against NNEBT in the Superior Court, the Cavanaghs made the

following relevant factual allegations:

Northern New England Benefit Trust, through its agents, notified plaintiffs’ counsel that it claimed liens on plaintiffs’ recoveries. Subject to New Hampshire law of proration of costs and fees and the doctrine of equitable apportionment, plaintiffs’ counsel acknowledged said liens.

As funds were received by plaintiffs’ counsel, he began negotiations with Northern New England Benefit Trust . . . to pay the liens claimed by Northern New England Benefit Trust.

Northern New England Benefit Trust refused to accept the standard New Hampshire practice of reducing the lien by one-third to cover the lienor’s share of

5 attorney’s fees. Northern New England Benefit Trust refused to pay any portion of costs incurred in obtaining the $200,000 in payments.

Plaintiffs’ counsel also sought “equitable apportionment” of the collected funds. Dimick v . Lewis, 127 NH 141 (1985).

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Cite This Page — Counsel Stack

Bluebook (online)
2013 DNH 035, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cavanagh-v-northern-ne-benefit-trust-nhd-2013.