CRUZ v. RELIANCE STANDARD LIFE INSURANCE COMPANY (2021)

United States Court of Appeals, Tenth Circuit.2021-09-01No. No. 21-2018

Summary · law.co

Holding. The court affirmed the district court's judgment, holding that ERISA benefit recovery actions are equitable rather than legal in nature and thus do not trigger Seventh Amendment jury trial rights.

A physician insured under a long-term disability policy sought judicial review after the insurance carrier denied his benefits claim. The insured argued that he was entitled to a jury trial under the Seventh Amendment to challenge medical records he believed were inaccurate, contending that ERISA's framework improperly deprived him of this constitutional right.

The appellate court rejected this argument, holding that ERISA benefit recovery actions are equitable in nature rather than legal claims, and therefore fall outside the scope of the Seventh Amendment's jury trial guarantee. The court noted it was bound by prior circuit precedent establishing this principle and found no superseding Supreme Court authority that would permit reconsideration of that precedent. Because the insured's sole request on appeal was to overturn the statutory framework governing jury rights in ERISA cases, the court could not grant the relief requested.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether ERISA benefit denial actions are legal or equitable claims
Whether the Seventh Amendment guarantees a jury trial in ERISA cases
Whether circuit precedent on ERISA and jury rights remained binding absent Supreme Court reversal

Procedural posture

The insured appealed the district court's de novo review upholding the insurance company's benefits denial decision.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

ORDER AND JUDGMENT *

Defendant Reliance Standard Life Insurance Company denied long-term disability insurance benefits to one of its insureds, Plaintiff Eldie L. Cruz, M.D., prompting Cruz to bring this action under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. §§ 1001–1461. The district court reviewed the insurance companys decision de novo, upheld it, and entered final judgment against Cruz. He timely filed a notice of appeal (we therefore have jurisdiction under 28 U.S.C. § 1291), and he has represented himself before this court.

Cruz tells us, “The only argument I want to make is that I feel like the 7th amendment of the U.S. Constitution doesnt include me after what has happened in this case.” Aplt. Opening Br. at 2. Drawing on his experience as a practicing physician, Cruz explains that medical records are frequently wrong because, for example, “things get heard wrong, doctors dont write [their] notes right away, they cut and paste from other notes ․, [and] they confuse one patient with another.” Id. at 1. Cruz believes he should have had an opportunity to demonstrate as much to a jury, so he asks us to “uphold [his] 7th amendment right by striking down the part of ERISA that denies a trial by jury.” Id. at 3.

ERISA does not explicitly deny a trial by jury. This court holds, however, that an action to recover ERISA-governed benefits is equitable, not legal, and so does not fall within the Seventh Amendments civil jury trial guarantee. See Adams v. Cyprus Amax Minerals Co., 149 F.3d 1156, 1158–62 (10th Cir. 1998); see also Graham v. Hartford Life & Acc. Ins. Co., 589 F.3d 1345, 1355–57 (10th Cir. 2009) (reaffirming Adams over an argument that an intervening Supreme Court decision had abrogated it). “[W]e cannot overrule the judgement of another panel of this court absent en banc reconsideration or a superseding contrary decision by the Supreme Court.” Burlington N. & Santa Fe Ry. Co. v. Burton, 270 F.3d 942, 947 (10th Cir. 2001). By definition this panel is not sitting en banc, and Cruz has not pointed us to any superseding Supreme Court authority, nor are we aware of any. Accordingly, we may not grant the only relief he requests. We therefore affirm the district courts judgment.

Carolyn B. McHugh, Circuit Judge