Edward Asner v. The Sag-Aftra Health Fund

CourtDistrict Court, C.D. California
DecidedOctober 19, 2023
Docket2:20-cv-10914
StatusUnknown

This text of Edward Asner v. The Sag-Aftra Health Fund (Edward Asner v. The Sag-Aftra Health Fund) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Edward Asner v. The Sag-Aftra Health Fund, (C.D. Cal. 2023).

Opinion

JS-6 1

6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA

11 EDWARD ASNER, et al., Case No. 2:20-cv-10914-CAS-JEMx 12 Plaintiffs, 13 CLASS ACTION vs. 14 THE SAG-AFTRA HEALTH FUND, FINAL ORDER APPROVING 15 et al., CLASS ACTION SETTLEMENT

16 Defendants. AND JUDGMENT [DKT. 158]

17 Judge: Hon. Christina A. Snyder 18 19 20 On January 1, 2017, the Screen Actors Guild-Health Plan (the “SAG Health 21 Plan”) merged with the American Federation of Television and Radio Artists Health 22 Plan (the “AFTRA Health Plan”) to create the SAG-AFTRA Health Plan (the 23 “Plan”). This case arises from the aftermath of the August 2020 amendments (the 24 “Amendments”) to the Plan, which were implemented to cut costs by changing the 25 Plan’s benefit structure and eligibility requirements. As a result, many Plan 26 participants lost coverage. 27 /// 1 Plaintiffs are participants and beneficiaries of the Plan and individuals that 2 qualified for coverage under the Plan between January 1, 2017, and May 3, 2023 3 (the “Settlement Class”). On December 1, 2020, plaintiffs filed this class action 4 against the trustees of the SAG Health Plan and the SAG-AFTRA Health Plan (the 5 “Trustees”) pursuant to the Employee Retirement Income Security Act of 1974, 29 6 U.S.C. § 1001, et seq. (“ERISA”) alleging breaches of fiduciary duties. The Trustees 7 dispute these claims. 8 On April 10, 2023, plaintiffs submitted an unopposed motion for preliminary 9 approval of class settlement along with a proposed settlement notice (the “Settlement 10 Notice”). Dkt. 127, 128-1. 11 On May 3, 2023, the Court granted plaintiffs’ motion for preliminary approval 12 of class settlement (the “Preliminary Approval Order”), approved a plan for 13 dissemination of the Settlement Notice, and set a Fairness Hearing for September 14 11, 2023. Dkt. 134. 15 On July 12, 2023, plaintiffs submitted a motion for final approval of (1) a final 16 Settlement Agreement, (2) attorneys’ fees, (3) expense reimbursement, and (4) 17 service awards for class representatives (the “Final Approval Motion”). Dkt. 141. 18 Defendants have opposed only the request for attorneys’ fees. Dkt. 149 (“Opp.”). 19 On September 11, 2023, the Court held the Fairness Hearing. Dkt. 156. The 20 Court has considered: (i) the Final Approval Motion; (ii) the extensive memoranda 21 of points and authorities submitted in support; (iii) the declarations and exhibits 22 submitted in support; (iv) defendants’ opposition to class counsel’s motion for 23 attorneys’ fees; (v) the Settlement Agreement itself; (vi) the entire record in this 24 proceeding, including but not limited to the points and authorities, declarations, and 25 exhibits submitted in support of preliminary approval of the settlement; (vii) the 26 form and manner of the Settlement Notice provided to the Settlement Class; (viii) 27 two objections to the settlement, one of which was not intended as a request to reject 1 the settlement; (ix) the arguments advanced by all objectors and the responses 2 provided by class counsel regarding each of the objections; (x) the absence of any 3 objection or response by any state attorneys general, nor insurance officials from any 4 state, after they were provided with notices required by the Class Action Fairness 5 Act of 2005, 28 U.S.C. § 1715; (xi) the oral presentation by both class counsel and 6 defendants’ counsel at the Fairness Hearing; (xii) the oral remarks by class member 7 Jan Hoag at the Fairness Hearing; (xiii) this Court’s observations while presiding 8 over this action and similar actions; and (xiv) the relevant law. 9 Based upon the foregoing considerations, the Court hereby ORDERS that the 10 Final Approval Motion be GRANTED on the terms set forth in this Final Approval 11 Order. 12 I. BACKGROUND. 13 A. Pre-Amendments. 14 In 2017, the SAG Health Plan and the AFTRA Health Plan merged to form 15 the Plan. Dkt. 46 at 3. 16 From 2017-2020, participants could qualify for coverage under the Plan in 17 several ways.1 Id. First, participants could receive active coverage through “Earned 18 Eligibility” i.e., by meeting certain earnings thresholds. Dkt. 46 at 4. As a general 19 matter, performers earn both “sessional earnings” (wages earned for services 20 performed on a certain day) and “residual earnings” (compensation for prior work 21 that is exhibited at a later point in time). Dkt. 46 at 3. Before the Amendments, 22 performers could count both types of earnings towards the earned-eligibility 23 threshold if they had at least $1 in sessional earnings for that year (the “Dollar 24 Sessional Rule”). Dkt. 141 at 1. 25

26 1 These benefits were subject to change. The Plan provided that future benefits “are 27 not promised, vested or guaranteed,” and reserved the right to “reduce, modify or discontinue benefits or the qualification rules for benefits at any time.” Dkt. 46 at 5. 1 Second, participants that did not have enough earnings to meet the earned- 2 eligibility threshold could still qualify for coverage if they met the “Age & Service” 3 eligibility rule requirements. Dkt. 47 at 295. The Age & Service qualification 4 applied to performers age 40 and older with at least 10 retiree health credits. Id. 5 Third, participants that did not have any sessional earnings could still qualify 6 for insurance coverage secondary to Medicare if they had the requisite residual 7 earnings. Dkt. 46 at 4-5. 8 Finally, performers who were at least 65 years old (“Senior Performers”) and 9 receiving a pension (and their dependents and surviving spouses) could qualify for 10 secondary insurance coverage through “Senior Performer Coverage” if they accrued 11 a certain number of years of vested pension credit. Dkt. 43 at 51. 12 B. Post-Amendments. 13 On August 12, 2020, the Plan announced several important changes to the 14 Plan’s benefit structure and eligibility requirements, citing increases in health costs 15 and projected loss of contributions during the pandemic. Dkt. 46 at 5. 16 Some changes affected all participants, including: collapsing the two benefit 17 levels into one; requiring spouses to take their own employer’s health coverage as 18 their primary coverage; raising participant premiums; combining the medical and 19 hospital out-of-network deductibles; and eliminating the out-of-network out-of- 20 pocket maximum. Id. 21 Other changes affected Senior Performers specifically. First, the 22 Amendments eliminated the Dollar Sessional Rule for Senior Performers who were 23 taking pension. Dkt. 141 at 8. As a result, participants in this group could no longer 24 count residual earnings towards the earned-eligibility threshold, even though such 25 earnings were still used to calculate employer contributions. Dkt. 43 at 86; dkt. 46 26 at 6. 27 1 Second, the Amendments replaced “Senior Performer Coverage” with a 2 newly-created Reimbursement Account Plan (the “HRA Plan”). Dkt. 46 at 6. Senior 3 Performers, and their age 65+ spouses and surviving spouses, would no longer 4 receive secondary coverage from the Plan; instead, they would receive either $240 5 or $1,140 per year from the HRA Plan to help cover the cost of obtaining 6 replacement coverage. Dkt. 141 at 3. 7 Plaintiffs allege there were additional detrimental changes, including changes 8 to the Age & Service eligibility criteria, base earnings years, and benefit periods. 9 Dkt. 43 at ¶ 89-91. 10 II. SETTLEMENT AGREEMENT 11 A. Definitions. 12 The capitalized terms used in this Final Approval Order shall have the 13 meanings and/or definitions given to them in the Settlement Agreement [Dkt. 128- 14 1], or if not defined therein, the meanings and/or definitions given to them in this 15 Final Approval Order. 16 B. Incorporation of Documents.

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Bluebook (online)
Edward Asner v. The Sag-Aftra Health Fund, Counsel Stack Legal Research, https://law.counselstack.com/opinion/edward-asner-v-the-sag-aftra-health-fund-cacd-2023.