Keith Singletary v. State Farm Fire & Casualty Co.

CourtLouisiana Court of Appeal
DecidedApril 23, 2008
DocketCA-0007-1347
StatusUnknown

This text of Keith Singletary v. State Farm Fire & Casualty Co. (Keith Singletary v. State Farm Fire & Casualty Co.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Keith Singletary v. State Farm Fire & Casualty Co., (La. Ct. App. 2008).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

CA 07-1347

KEITH SINGLETARY, ET AL.

VERSUS

STATE FARM FIRE & CASUALTY CO., ET AL.

**********

APPEAL FROM THE ELEVENTH JUDICIAL DISTRICT COURT PARISH OF SABINE, NO. 55,040 HONORABLE STEPHEN BRUCE BEASLEY, DISTRICT JUDGE

JOHN D. SAUNDERS JUDGE

Court composed of Ulysses Gene Thibodeaux, Chief Judge, John D. Saunders, and Glenn B. Gremillion, Judges.

REVERSED IN PART AND AFFIRMED IN PART.

William Preston Crews, Jr. Attorney at Law P. O. Box 226 Natchitoches, LA 71458-0226 (318) 356-8001 Counsel for Defendant/Appellant: Conagra Poultry Company

Craig Alan Davis Attorney at Law 111 Mercury Lafayette, LA 70503 (337) 231-5351 Counsel for Plaintiffs/Appellees: Keith Singletary Belinda Singletary SAUNDERS, Judge.

FACTS AND PROCEDURAL HISTORY:

On May 4, 2001, then fifteen-year-old Mary Peterson (hereinafter “Ms.

Peterson”) was involved in an automobile accident from which she sustained severe

bodily injury. Ms. Peterson was transported by MedExpress ambulance to

Natchitoches Parish Hospital, and then flown by Life Air Rescue helicopter to LSU

Health Sciences Center in Shreveport (hereinafter “LSUS”), where she remained in

intensive care for over a month. Due to the severity of Ms. Peterson’s injuries, the

medical bills she incurred totaled nearly $250,000.00.

At the time of the accident, Ms. Peterson’s father, Mr. Keith Singletary

(hereinafter “Mr. Singletary”), was employed by defendant ConAgra Poultry

Company (later acquired by Pilgrims Pride Corporation, both hereinafter referred to

as “ConAgra”). As part of its employee benefits package, ConAgra provided health

insurance coverage in the form of the ConAgra Employee Benefit Plan (hereinafter

“Benefit Plan”), which was administered by Blue Cross Blue Shield of Nebraska

(hereinafter “BCBSN”). Stemming in part from ConAgra’s alleged failure to timely

repay medical bills under the Benefit Plan, Mr. Singletary and his wife, Ms. Belinda

Singletary (hereinafter collectively “plaintiffs”) brought suit on May 3, 2002, in the

Eleventh Judicial District Court, in Sabine Parish, Louisiana. Plaintiffs sought

payment of bills as well as attorney’s fees.

After years of litigation, plaintiffs and ConAgra finally participated in a one-

day bench trial before Judge Stephen Beasley (hereinafter “Judge Beasley”) in July

2007, with the only issue being the plaintiffs’ claim against ConAgra for payment of

medical bills. At trial, Mr. Singletary testified that although the majority of the

$59,112.76 in medical bills owed to LSUS were incurred during the months of May and June 2001, they were not paid under the Benefit Plan until March 2003.

Plaintiffs argued that they were thus entitled to statutory penalties and attorney’s fees

under La.R.S. 22:657(A), the enforcement provision of the Louisiana Insurance Code.

As an affirmative defense, ConAgra argued that La.R.S. 22:657(A) was preempted

by the federal Employee Retirement Income Security Act of 1964 (hereinafter

“ERISA”). 29 U.S.C. § 1001, et seq.

ASSIGNMENTS OF ERROR:

1) Did the trial court commit manifest error in finding that ConAgra did not meet

its burden of proof in establishing its affirmative defense that the Benefit Plan

was an “ERISA plan?”

2) Did the trial court commit manifest error in employing considerations of

whether or not the Benefit Plan was funded or unfunded to determine that the

Benefit Plan was not an “ERISA plan?”

3) Did the trial court commit manifest error in awarding plaintiffs statutory

penalties and attorney’s fees under La.R.S. 22:657?

4) Did the trial court commit manifest error in concluding that certain medical

bills at issue here had not been timely processed and paid?

ASSIGNMENT OF ERROR #1:

In its first assignment of error, ConAgra argues that the trial court erred in

finding that it failed to meet its burden of proof in establishing the affirmative defense

that the Benefit Plan was an “ERISA plan.” More particularly, ConAgra asserts that

the inclusion of its “Poultry Company Medical Plan PM23F” (hereinafter “Plan

Booklet”) in the record precluded the trial court from reasonably concluding that the

Benefit Plan was not an “ERISA plan,” thus preempting the applicability of La.R.S.

2 22:657(A). We agree.

The United States District Court for the Western District of Louisiana

previously discussed the preemptive effect of ERISA on state laws in Rasmussen v.

Metropolitan Life Insurance Co., 675 F.Supp. 1497 (W.D. La. 1987). There, the

court proclaimed:

The ERISA preemption clause provides that ERISA “shall supersede any and all State laws insofar as they may now or hereafter relate to any employee benefit plan described in § 1003(a) of this title and not exempt under §1003(b) of this title.” 29 U.S.C. § 1144(a). Thus if the employee benefits do not constitute a “plan” within the meaning of ERISA, the preemption inquiry ends. Likewise, if the state law does not “relate to” an ERISA plan, preemption will not occur. The definition of an ERISA plan is codified in § 1002(1), and was summarized in Donovan v. Dillingham, 688 F.2d 1367, 1373 (11th Cir.1982), as follows: [A] ‘plan, fund, or program’ under ERISA is established if from the surrounding circumstances a reasonable person can ascertain the intended benefits, a class of beneficiaries, the source of financing, and procedures for receiving benefits. To be an employee welfare benefit plan, the intended benefits must be health, . . . the intended beneficiaries must include union members, employees, former employees, or their beneficiaries; and an employer or employee organization, or both, and not individual employees or entrepreneural [sic] businesses, must establish or maintain the plan, fund, or program.

Id. at 1500 (footnote omitted). Thus, in order for employee benefits to qualify under

ERISA, they must first satisfy the requirements for an “ERISA plan” under Donovan.

ConAgra argues that its Benefit Plan satisfies these requirements. We agree.

As evidenced by the Plan Booklet—entered into the record as plaintiffs’ “Exhibit

3”—the Benefit Plan was established by ConAgra for the intended purpose of

providing health benefits to employees and their eligible dependents. With respect

to the Benefit Plan’s source of financing, the Plan Booklet clearly states: “The plan

is funded by ConAgra Poultry Company and participating employees through a trust

agreement with: State Street Bank and Trust Company.” Moreover, the Plan Booklet

3 outlines clearly the procedures for receiving benefits, under the section bearing the

heading “How to File a Claim.” In sum, the Benefit Plan satisfies all prerequisites for

qualifying as an “ERISA plan” under Donovan.

In addition to meeting the substantive requirements for an “ERISA plan,” we

note further that the Plan Booklet contains a section entitled “Your ERISA Rights.”

That section begins: “The ConAgra Poultry Company Medical Plan provides rights

and protections to employees under the Employee Retirement Income Security Act

of 1974 (ERISA).” The section goes on to provide a mechanism for employees’ free

review of “all plan documents,” a mailing address from which copies of “all plan

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