William McNeil, individually and on behalf of all others similarly situated v. Marriott International, Inc. and Marriott International, Inc. Corporate Benefits Department

District Court, D. Maryland·Decided August 18, 2026·No. 8:25-cv-02975·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND.

WILLIAM MeNEIL, individually and on behalf of all others ~ similarly situated, Plaintiff, vo _ Civil Action No. 25-2975-TDC MARRIOTT INTERNATIONAL, INC. and □ MARRIOTT INTERNATIONAL, INC. CORPORATE BENEFITS DEPARTMENT, Defendants. □□

_ MEMORANDUM OPINION Plaintiff William McNeil has filed this putative class action against his employer, Marriott. International, Inc. (“Marriott”), and the Marriott Corporate Benefits Department (“the Benefits Department”), in which he alleges that Defendants required tobacco users to pay an unlawful surcharge for healthcare coverage, failed to provide adequate notice.relating to that surcharge, □□□ breached their fiduciary duties in their.treatment of the funds collected from that surcharge, in violation of various provisions of the Employee Retirement Income Security Act of 1974. □ (“ERISA”), 29 U.S.C. §§ 1001-1193c; the Public Health Service Act (“PHSA”), 42 U.S.C. §§ 300gg—300gg-139; and related regulations. Defendants have filed a Motion to Dismiss the Amended Class Action Complaint, which is fully briefed. Having reviewed the submitted materials, the Court finds that no hearing is necessary. See D. Md. Local. R. 105.6. Forthe reasons set forth below, the Motion will be GRANTED IN PART and DENIED IN PART.

es sues BACKGROUND --—- □□□ I. Statutory F ramework . ERISA and the PHSA prohibit any group health plan from requiring certain participants to, higher premium based ona “health status-related factor.” 29-U.S.C. § 1 182(b)(1); 42 USC.

§ 300ge-4(b)(1). Specifically, those statutes state that; © A group health plan... may not require any individual (asa condition of enrollment or continued enrollment under the plan) to pay a premium or contribution which is greater than such premium or contribution 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 individual.enrolled under the plan as a dependent of the □ individual. . 29 U.S.C, § ] 182(b)(1); 42 US.C. § 300g8-4(b)(1). A group health plan may, however, establish “premium discounts or rebates or modify[] otherwise applicable copayments: or deductibles in return for adherence to programs of health promotion and disease prevention.” 29 U.S.C. § 1182(b)(2); 42 US.C. § 300g8-4(b)(2). . The PHSA places certain conditions on such programs of health promotion and disease

prevention. See 29 U.S.C. § 1185d(a)(1) (stating that certain provisions of the PHSA “shall apply to group health plans, and ‘health insurance. issuers providing health insurance coverage in connection with group health plans”). Specifically, the PHSA provides that “[i}f any of the

conditions for obtaining a premium discount or rebate or other reward for participation in a wellness program is Based on an individual satisfying a standard that is related to a health status factor,” that wellness program must comply with certain requirements. 42 U.S.C. § 300gg- 4G)C)(C). Those requirements include that: . The full reward under the wellness program shall be ‘made available to all □□ similarly situated individuals. For such purpose, among other things: @ The reward is not available to all similarly situated individuals for a period unless the wellness program allows— -

(1) for a reasonable alternative standard (or waiver of the otherwise applicable standard) for obtaining the reward for any individual for whom, for that period, it is unreasonably difficult due to a medical condition to satisfy the otherwise applicable standard; and (Il) for a reasonable alternative standard (or waiver of the otherwise applicable standard) for obtaining the reward for any individual for . whom, for that period, it is medically inadvisable to attempt to satisfy the otherwise applicable standard. 42 U.S.C. § 300gg-4G)(3)(D). . The regulatory framework for “[p]rohibiting discrimination against participants beneficiaries based on a health factor” further defines the contours of a reasonable alternative standard. ‘29 C.F.R. § 2590.702; 45 C.F.R. § 146.121. Those requirements differ depending on the type of “wellness program” that the group health plan requires in order to obtain a “reward,” which the regulations define as including “avoiding a penalty (such as the absence of a premium - surcharge or other financial or nonfinancial disincentive).” 29 C.F.R. § 2590.702(f(1)G); 45 □ CER. § 146.121(£)(1)(i). As relevant here: An outcome-based wellness program is a type of health-contingent wellness’ _ "program that requires an individual to attain or maintain a specific health outcome (such as not smoking of attaining certain results on biometric screenings) in order to obtain a reward. To comply with the rules of this paragraph (f), an outcome- based wellness program typically has two tiers. That is, for individuals who do not attain or maintain the specific health outcome, compliance with an educational □ program or an activity may be offered as an alternative to achieve the same reward. This alternative pathway, however, does not mean that the overall program, which has an outcome-based component, is not an outcome-based wellness program. That is, if a measurement, test, or screening is used:as part of an initial standard and individuals who meet the standard are granted the reward, the program is _ considered an outcome-based wellness program. . 29 C.F.R. § 2590.702(f)(1)(v); 45 CER. § 146.121(6)(1)(v). “The full reward under [an] outcome- □

based wellness program must be available to all similarly situated individuals.” 29 C.F.R. § 2590.702((4)(iv); 45 C.F.R. § 146.121()(4)Gv). In addition: —

[A] reward under an outcome-based wellness program is not available to all similarly situated individuals for a period unless the program allows a reasonable alternative standard (or waiver of the otherwise applicable standard) for obtaining the reward for any individual who does not meet the initial standard based on the measurement, test, or screening. ° ' 29 C.F.R. § 2590.702(f)(4)(iv)(A); 45 CFR. § 146.121(£)(4)(iv)(A).

_ The PHSA also imposes a requirement that a group health plan provide notice of the availability of a reasonable alternative standard:

Free access — add to your briefcase to read the full text and ask questions with AI

William McNeil, individually and on behalf of all others similarly situated v. Marriott International, Inc. and Marriott International, Inc. Corporate Benefits Department, (D. Md. 2026).

William McNeil, individually and on behalf of all others similarly situated v. Marriott International, Inc. and Marriott International, Inc. Corporate Benefits Department (William McNeil, individually and on behalf of all others similarly situated v. Marriott International, Inc. and Marriott International, Inc. Corporate Benefits Department) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Massachusetts Mutual Life Insurance v. Russell
473 U.S. 134 (Supreme Court, 1985)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
LOCKHEED CORP. Et Al. v. SPINK
517 U.S. 882 (Supreme Court, 1996)
LaRue v. DeWolff, Boberg & Associates, Inc.
552 U.S. 248 (Supreme Court, 2008)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
CGM, LLC v. BellSouth Telecommunications, Inc.
664 F.3d 46 (Fourth Circuit, 2011)
Elena David v. J. Alphin
704 F.3d 327 (Fourth Circuit, 2013)
Phelps v. CT Enterprises, Inc.
194 F. App'x 120 (Fourth Circuit, 2006)
DiFelice v. U.S. Airways, Inc.
497 F.3d 410 (Fourth Circuit, 2007)
Roman Zak v. Chelsea Therapeutics International
780 F.3d 597 (Fourth Circuit, 2015)
Belmora LLC v. Bayer Consumer Care AG
819 F.3d 697 (Fourth Circuit, 2016)
Michael Dreher v. Experian Information Solutions
856 F.3d 337 (Fourth Circuit, 2017)
Kay Ansley v. Marion Warren
861 F.3d 512 (Fourth Circuit, 2017)
State of South Carolina v. United States
912 F.3d 720 (Fourth Circuit, 2019)
Krakauer v. Dish Network, L. L.C.
925 F.3d 643 (Fourth Circuit, 2019)
TransUnion LLC v. Ramirez
594 U.S. 413 (Supreme Court, 2021)
Coyne & Delany Co. v. Selman
98 F.3d 1457 (Fourth Circuit, 1996)