Minda D. Wiederhold individually and on behalf of all others similarly situated v. Res-Care, Inc. d/b/a BrightSpring Health Services

CourtDistrict Court, S.D. Indiana
DecidedMarch 31, 2026
Docket4:24-cv-00003
StatusUnknown

This text of Minda D. Wiederhold individually and on behalf of all others similarly situated v. Res-Care, Inc. d/b/a BrightSpring Health Services (Minda D. Wiederhold individually and on behalf of all others similarly situated v. Res-Care, Inc. d/b/a BrightSpring Health Services) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Minda D. Wiederhold individually and on behalf of all others similarly situated v. Res-Care, Inc. d/b/a BrightSpring Health Services, (S.D. Ind. 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA NEW ALBANY DIVISION

MINDA D. WIEDERHOLD individually and ) on behalf of all others similarly situated, ) ) Plaintiff, ) ) v. ) No. 4:24-cv-00003-SEB-TAB ) RES-CARE, INC. d/b/a BRIGHTSRPING ) HEALTH SERVICES, ) ) ) Defendant. )

ORDER GRANTING DEFENDANT'S MOTION FOR SUMMARY JUDGMENT

Plaintiff Minda D. Wiederhold ("Ms. Wiederhold") brought this putative class ac- tion against her former employer, Defendant Res-Care, Inc. d/b/a BrightSpring Health Ser- vices ("Res-Care"),1 for alleged violations of the Employment Retirement Income Security Act ("ERISA"), 29 U.S.C. § 1001 et seq. Now before the Court is Res-Care's Motion for Summary Judgment on all claims. Dkt. 28. For the reasons explained below, that motion is GRANTED. LEGAL STANDARD Summary judgment is proper when "the movant shows that there is no genuine dis- pute as to any material fact and that the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a). The summary judgment standard requires "no genuine issue of

1 For purposes of this order, we shall refer to Defendant as "Res-Care," though the record evidence does contain numerous references to "BrightSpring" as well. material fact," meaning that "the mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment."

Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247−48 (1986) (emphasis in original). Ma- terial facts are those that "might affect the outcome of the suit," and a dispute of material fact is genuine when "a reasonable jury could return a verdict for the nonmoving party." Id. at 248. When deciding whether a genuine dispute of material fact exists, the court con- strues all facts in the light most favorable to the non-moving party and draws all reasonable inferences in that party's favor. Khungar v. Access Cmty. Health Network, 985 F.3d 565,

572 (7th Cir. 2021). BACKGROUND I. Overview of ERISA's Nondiscrimination Rules ERISA contains a nondiscrimination provision prohibiting group health plans, such as that offered by Res-Care, from charging participants with health-status related premi-

ums. See 29 U.S.C. § 1182(b). Specifically, § 1182(b)(1) provides as follows: A group health plan, and a health insurance issuer offering health insurance coverage in connection with a group health plan, may not require any indi- vidual (as a condition of enrollment or continued enrollment under the plan) to pay a premium or contribution which is greater than such premium or con- tribution for a similarly situated individual enrolled in the plan on the basis of any health status-related factor in relation to the individual or to an indi- vidual enrolled under the plan as a dependent of the individual.

Id. (emphasis added). Paragraph (b)(2)(B), however, creates an exception to this general restriction: It states that "[n]othing in paragraph (1) shall be construed . . . to prevent a group health plan, and a health insurance issuer offering group health insurance coverage, from establishing premium discounts or rebates . . . in return for adherence to programs of health promotion and disease prevention" (a/k/a "wellness programs"). Id. § 1182(b)(2)(B). Thus, although ERISA bars discrimination, it does not prohibit employers or insurers from

offering premium discounts in exchange for participation in a bona fide wellness program. To meet the requirements of the exception under paragraph (b)(2)(B), a wellness program must adhere to certain statutory requirements. As relevant to the case at bar, such requirements include as follows: "[t]he full reward[2] . . . shall be made available to all similarly situated individuals," meaning that "the wellness program allows . . . for a rea- sonable alternative standard . . . for obtaining the reward"; and the plan must "disclose in

all plan materials describing the terms of the wellness program the availability of a reason- able alternative standard." 42 U.S.C. §§ 300gg-4(j)(1)(C), (j)(3)(D)–(E).3 "If plan materials disclose that such a program is available, without describing its terms, the disclosure [de- scribed herein] shall not be required. Id. § 300gg-4(j)(3)(E). The applicable federal regulations similarly require that "[t]he full reward under [an]

outcome-based wellness program[4] must be available to all similarly situated individuals." 29 C.F.R. § 2590.702(f)(4)(iv). Regarding notice, "[t]he plan or issuer must disclose in all plan materials describing the terms of an outcome-based wellness program, and in any

2 A "reward" in this context means "a discount or rebate of a premium or contribution, a waiver of all or part of a cost-sharing mechanism, an additional benefit, or any financial or other incentive" as well as avoidance of a penalty (i.e., a surcharge). 29 C.F.R. § 2590.702(f)(1)(i). 3 Section 2705 of the Public Health Safety Act (the "PHSA"), codified at 42 U.S.C. § 300gg-4, was incorporated into ERISA in 2010. See 29 U.S.C. § 1185(d)(a)(1). 4 "An outcome-based wellness program is a type of health-contingent wellness program that re- quires an individual to attain or maintain a specific health outcome (such as not smoking or attain- ing certain results on biometric screenings) in order to obtain a reward." 29 C.F.R. § 2590.702(f)(1)(v). disclosure that an individual did not satisfy an initial outcome-based standard, the availa- bility of a reasonable alternative standard to qualify for the reward . . . ." 29 C.F.R. §

2590.702(f)(4)(v). However, "[i]f plan materials merely mention that such a program is available, without describing its terms, this disclosure is not required." Id.; see also Incen- tives for Nondiscriminatory Wellness Programs in Group Health Plans, 78 Fed. Reg. 33158-01, 33160 (June 3, 2013) (describing this criteria "must be satisfied in order for the plan or issuer to qualify for an exception to the prohibition on discrimination based on health status"). These regulatory guidelines "set forth criteria for an affirmative defense

that" plans and issuers may invoke "in response to a claim that a plan or issuer discrimi- nated under the [applicable] nondiscrimination provisions." Incentives for Nondiscrimina- tory Wellness Programs in Group Health Plans, 78 Fed. Reg. at 33160. II. The Parties Res-Care is a home- and community-based health services enterprise that serves

individuals in need of specialized medical care. Ms. Wiederhold worked at Res-Care for approximately twelve years from October 2011 through October 2023. Ernst Decl. ¶ 8, dkt. 30-1 (Declaration of Shannon Ernst). At all times relevant to this litigation, Ms. Wiederhold has been a tobacco user. Wiederhold Dep. 13:6–14, dkt. 30-12. During Ms.

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68 F.4th 345 (Seventh Circuit, 2023)

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