Brief-Writing Tips from Circuit Judge Stanley F. Birch, Jr.

For those who have not done so already, you can access How Appealing's 20 Questions for Circuit Judge Stanley F. Birch, Jr. of the U.S. Court of Appeals for the Eleventh Circuit here. In response to Howard's question regarding what…

For those who have not done so already, you can access How Appealing’s 20 Questions for Circuit Judge Stanley F. Birch, Jr. of the U.S. Court of Appeals for the Eleventh Circuit here. In response to Howard’s question regarding what makes a good brief, I particularly enjoyed the following comments:

That is a tough question. The truly outstanding briefs are those that succinctly and with straight-forward clarity relate the existing law to their case. Too much time is spent, even in good briefs, reviewing legal principles with which most judges are familiar. I have proposed that each circuit publish a web-site on which the “boilerplate” for each area of law in that circuit is contained and referenced by an identifying number — much like standard jury charges. A committee of judges and/or staff attorneys could maintain the currency of the citations and text. In briefs all of those familiar legal principles could simply be enumerated (and perhaps “jump-cited” for the benefit of law clerks or new judges) thereby reducing the volume of reading and compelling counsel to focus on applying the law to the circumstances in the case before us. I have waded through pages chronicling the shifting burdens in an employment discrimination case only to be presented with a couple of paragraphs relating all of that law to the facts in the case on appeal.

The suggestion for circuit “boilerplate” is a great one, in my opinion. It would not only help judges, but also the lawyers who write the briefs and the clients who pay their bills.

Brief-Writing Tips from Circuit Judge Stanley F. Birch, Jr.

For those who have not done so already, you can access How Appealing's 20 Questions for Circuit Judge Stanley F. Birch, Jr. of the U.S. Court of Appeals for the Eleventh Circuit here. In response to Howard's question regarding what…

For those who have not done so already, you can access How Appealing’s 20 Questions for Circuit Judge Stanley F. Birch, Jr. of the U.S. Court of Appeals for the Eleventh Circuit here. In response to Howard’s question regarding what makes a good brief, I particularly enjoyed the following comments:

That is a tough question. The truly outstanding briefs are those that succinctly and with straight-forward clarity relate the existing law to their case. Too much time is spent, even in good briefs, reviewing legal principles with which most judges are familiar. I have proposed that each circuit publish a web-site on which the “boilerplate” for each area of law in that circuit is contained and referenced by an identifying number — much like standard jury charges. A committee of judges and/or staff attorneys could maintain the currency of the citations and text. In briefs all of those familiar legal principles could simply be enumerated (and perhaps “jump-cited” for the benefit of law clerks or new judges) thereby reducing the volume of reading and compelling counsel to focus on applying the law to the circumstances in the case before us. I have waded through pages chronicling the shifting burdens in an employment discrimination case only to be presented with a couple of paragraphs relating all of that law to the facts in the case on appeal.

The suggestion for circuit “boilerplate” is a great one, in my opinion. It would not only help judges, but also the lawyers who write these briefs and the clients who pay their bills.

IRS Pension Limitations and the Social Security Contribution and Benefit Base for 2004

This from the Internal Revenue Service in IR-2003-122: "IRS Announces Pension Plan Limitations for 2004." Also, the Contribution and Benefit Base for 2004 from the Social Security Administration: $87,900. (Thanks to Benefitslink.com for the link.)…

This from the Internal Revenue Service in IR-2003-122: “IRS Announces Pension Plan Limitations for 2004.”

Also, the Contribution and Benefit Base for 2004 from the Social Security Administration: $87,900. (Thanks to Benefitslink.com for the link.)

ERISA preemption: a “Serbonian Bog”

Law.com reports: "Becker Calls on Congress, Justices to Fix ERISA." According to the article, 3rd Circuit Court Judge Edward Becker, "in his opening paragraph of a lengthy and powerfully worded concurring opinion" in DiFelice v. Aetna, states that he wants…

Law.com reports: “Becker Calls on Congress, Justices to Fix ERISA.” According to the article, 3rd Circuit Court Judge Edward Becker, “in his opening paragraph of a lengthy and powerfully worded concurring opinion” in DiFelice v. Aetna, states that he wants to add his voice “to the rising judicial chorus urging that Congress and the Supreme Court revisit what is an unjust and increasingly tangled ERISA regime.” The opinion is artfully written and a must-read for anyone interested in ERISA preemption.

Continue reading for the facts of the case as well as key portions from the opinion, including the answer to this question: “What is a Serbonian blog?” Judge Becker used the term in his opinion.

UPDATE: By the way, at the end of the opinion, Judge Becker writes:

The Clerk of Court is directed to send a copy of this opinion (with attention directed to the concurrence) to the Solicitor of the Department of Labor; the Chair, Ranking Member, Chief Majority Counsel, and Minority Counsel of the Senate Committee on Health, Education, Labor, and Pensions; and the Chair, Ranking Member, Chief Majority Counsel, and Minority Counsel of the House Committee on Education and the Workforce.

(This post should probably be entitled: “3rd Circuit Court Judge Becker has had it with ERISA!”)

Facts of the Case: According to the opinion, the plaintiff in the case was diagnosed with a condition which his doctor decided necessitated a specially designed breathing tube. The HMO allegedly instructed the doctor that the specially designed tube was not “medically necessary” so that the doctor used an alternative device which caused the plaintiff great difficulty. Plaintiff brought suit in state court alleging that the HMO negligently interfered with his medical care in two ways: (1) that the HMO instructed the doctor that the specially designed tube was not medically necessary and (2) that the HMO insisted that plaintiff be discharged from the hospital sooner than his doctor deemed advisable. The HMO removed the case to federal court and then moved to dismiss the complaint alleging that it was preempted by ERISA. The lower court granted the motion to dismiss and the plaintiff then appealed. The Third Circuit upheld the dismissal of the claim as to the first allegation of negligence, but reversed the District Court’s order dismissing the part of the claim pertaining to the discharge from the hospital:

Because [plaintiff’s] claim that [the HMO] interfered with his medical treatment by finding the special tracheostomy tube to be “medically unnecessary” could have been brought under section 502(a) of ERISA for the recovery of benefits due under his plan, it is completely preempted. We will therefore affirm the order of the District Court dismissing that claim. However, because [the HMO] has not shown that [plaintiff’s] claim that [the HMO] interfered with his medical treatment by insisting on his discharge from the hospital is based on any plan benefit, that claim is not completely preempted. We will therefore reverse the District Court’s order dismissing that claim and remand for further proceedings.

Judge Edward Becker then issued his concurring opinion (spanning 26 pages of the opinion). Key portions of the opinion:

1. “I am satisfied that Judge Rendell’s opinion reaches the correct result under our governing caselaw. While I thus join in her opinion and in the judgment, I write separately to add my voice to the rising judicial chorus urging that Congress and the Supreme Court revisit what is an unjust and increasingly tangled ERISA regime. Congress enacted ERISA in 1974 ‘to promote the interest of employees and their beneficiaries in employee benefit plans.’ . . However, with the rise of managed care and the Supreme Court’s series of decisions holding preempted any action for damages against HMOs, ERISA has evolved into a shield that insulates HMOs from liability for even the most egregious acts of dereliction committed against plan beneficiaries, a state of affairs that I view as directly contrary to the intent of Congress. Indeed, existing ERISA jurisprudence creates a monetary incentive for HMOs to mistreat those beneficiaries, who are often in the throes of medical crises and entirely unable to assert what meager rights they possess.

Lower courts have struggled to maintain some semblance of equity notwithstanding the enormous breadth of the preemption test, one that turns on whether the claim is ‘related to’ a benefit plan, inter alia, by identifying exceptions to section 514 preemption, such as that for medical malpractice liability. And in terms of the remedial scope of section 502, they have struggled to make sense out of the distinction between eligibility decisions (which are preempted) and medical decisions (which are not), a hopeless endeavor, as I shall explain. Unfortunately, the price of all this has been descent into a Serbonian bog wherein judges are forced to don logical blinders and split the linguistic atom to decide even the most routine cases.” (Footnote 1 to the concurring opinion explains that a “serbonian bog is a mess from which there is no way of extricating oneself.” According to the opinion, the Serbonian bog “was between Egypt and Palestine.” The footnote goes on to say that “Hume said that whole armies have been lost therein. . .”

2. “. . . ERISA generally, and section 514(a) particularly, have become virtually impenetrable shields that insulate plan sponsors from any meaningful liability for negligent or malfeasant acts committed against plan beneficiaries in all too many cases. This has unfolded in a line of Supreme Court cases that have created a ‘regulatory vacuum’ in which virtually all state law remedies are preempted but very few federal substitutes are provided.”

3. “. . .the root of courts’ ERISA preemption nightmare is that ERISA forces them to distinguish between eligibility and treatment decisions while providing a remedial structure that makes the two virtually synonymous. For participants, the torment is still greater: ERISA de facto places the HMO in control of the treatment a participant receives, yet it preempts any state-law medical malpractice claim against that HMO and provides that the participant can recover no compensatory, punitive, or wrongful-death damages regardless of its malfeasance. This situation has arisen because ERISA has failed to evolve to accommodate the rise of HMOs, which did not even exist when ERISA was enacted in 1974.”

4. “Even if Congress refuses to act, however, the Supreme Court, in its interpretive capacity, is capable of effecting salutary change in many ways. The Court has no crystal ball, and twenty years ago it could not have foreseen the radical changes that have overtaken the health care system, and the difficulties that its preemption decisions would create. The time might be right to reconsider the string of holdings, epitomized by Russell and Mertens, that rule out the possibility of recovering compensatory damages under ERISA section 503(a)(3). See generally John H. Langbein, What ERISA Means by “Equitable”: The Supreme Court’s Trail of Error in Russell, Mertens, and Great-West, Yale Law School Center for Law, Economics, and Public Policy, Research Paper No. 269.”

ERISA preemption: a “Serbonian Bog”

Law.com reports: "Becker Calls on Congress, Justices to Fix ERISA." According to the article, 3rd Circuit Court Judge Edward Becker, "in his opening paragraph of a lengthy and powerfully worded concurring opinion" in DiFelice v. Aetna, states that he wants…

Law.com reports: “Becker Calls on Congress, Justices to Fix ERISA.” According to the article, 3rd Circuit Court Judge Edward Becker, “in his opening paragraph of a lengthy and powerfully worded concurring opinion” in DiFelice v. Aetna, states that he wants to add his voice “to the rising judicial chorus urging that Congress and the Supreme Court revisit what is an unjust and increasingly tangled ERISA regime.” The opinion is artfully written and a must-read for anyone interested in ERISA preemption.

Continue reading for the facts of the case as well as key portions from the opinion, including the answer to this question: “What is a Serbonian blog?” Judge Becker used the term in his opinion.

UPDATE: By the way, at the end of the opinion, Judge Becker writes:

The Clerk of Court is directed to send a copy of this opinion (with attention directed to the concurrence) to the Solicitor of the Department of Labor; the Chair, Ranking Member, Chief Majority Counsel, and Minority Counsel of the Senate Committee on Health, Education, Labor, and Pensions; and the Chair, Ranking Member, Chief Majority Counsel, and Minority Counsel of the House Committee on Education and the Workforce.

(This post should probably be entitled: “3rd Circuit Court Judge Becker has had it with ERISA!”)

The Inside Scoop on Cash Balance Plans

"Treasury May Delay Pension Rules: White House Will Wait for Congress To Take Action on Cash-Balance Plans": the Wall Street Journal reports how "the Treasury Department may be backing off releasing long-awaited regulations on cash-balance pension plans, and will instead…

Treasury May Delay Pension Rules: White House Will Wait for Congress To Take Action on Cash-Balance Plans“: the Wall Street Journal reports how “the Treasury Department may be backing off releasing long-awaited regulations on cash-balance pension plans, and will instead wait for Congress to act before it proceeds.” The source of the information was an interview by Tax Analysts with Pam Olson, the assistant secretary for tax policy. (Tax Analysts reported the information on Wednesday.) The article also reports that the Journal confirmed this information with Treasury spokeswoman Tara Bradshaw who said that Ms. Olson had been accurately quoted in the Tax Analysts article, but added that the agency is still “working on the regulations — we’ve been looking at all the [court] rulings and all the comments and are trying to figure out how to proceed.”

The Inside Scoop on Cash Balance Plans

"Treasury May Delay Pension Rules: White House Will Wait for Congress To Take Action on Cash-Balance Plans": the Wall Street Journal reports how "the Treasury Department may be backing off releasing long-awaited regulations on cash-balance pension plans, and will instead…

Treasury May Delay Pension Rules: White House Will Wait for Congress To Take Action on Cash-Balance Plans“: the Wall Street Journal reports how “the Treasury Department may be backing off releasing long-awaited regulations on cash-balance pension plans, and will instead wait for Congress to act before it proceeds.” The source of the information was an interview by Tax Analysts with Pam Olson, the assistant secretary for tax policy. (Tax Analysts reported the information on Wednesday.) The article also reports that the Journal confirmed this information with Treasury spokeswoman Tara Bradshaw who said that Ms. Olson had been accurately quoted in the Tax Analysts article, but added that the agency is still “working on the regulations — we’ve been looking at all the [court] rulings and all the comments and are trying to figure out how to proceed.”

More on the Enron case . . .

Gardner, Carton & Douglas provides this article-"Enron Case Moves Forward: Plan Fiduciaries Should Take Note." You can read more about the recent Enron case-Tittle v. Enron Corp., 2003 WL 22245394 (S.D. Tex. Sept. 30, 2003)-in many previous posts which you…

Gardner, Carton & Douglas provides this article–“Enron Case Moves Forward: Plan Fiduciaries Should Take Note.” You can read more about the recent Enron case–Tittle v. Enron Corp., 2003 WL 22245394 (S.D. Tex. Sept. 30, 2003)–in many previous posts which you can access here.

More on the Enron case . . .

Gardner, Carton & Douglas provides this article-"Enron Case Moves Forward: Plan Fiduciaries Should Take Note." You can read more about the recent Enron case-Tittle v. Enron Corp., 2003 WL 22245394 (S.D. Tex. Sept. 30, 2003)-in many previous posts which you…

Gardner, Carton & Douglas provides this article–“Enron Case Moves Forward: Plan Fiduciaries Should Take Note.” You can read more about the recent Enron case–Tittle v. Enron Corp., 2003 WL 22245394 (S.D. Tex. Sept. 30, 2003)–in many previous posts which you can access here.

The Joint Committee On Taxation COLI Report

The Congressional Joint Committee on Taxation yesterday issued this report: "Present-law Federal Tax Treatment, Proposals, and Issues Relating to Company-Owned Life Insurance." Roth CPA calls it the "best short guide available to this arcane area of the tax law." The…

The Congressional Joint Committee on Taxation yesterday issued this report: “Present-law Federal Tax Treatment, Proposals, and Issues Relating to Company-Owned Life Insurance.” Roth CPA calls it the “best short guide available to this arcane area of the tax law.” The document was prepared in advance of hearings before the Senate Finance Committee which were supposedly to take place today on the proposal to eliminate the tax-free treatment of life insurance proceeds for former employees. It is my understanding that the hearings were postponed until next week.