Employment — ERISA; Anti-Injunction Act

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Employment — ERISA; Anti-Injunction Act

A federal court cannot enjoin an attorney and his clients from pursuing a state court claim against an employee health and welfare benefit plan governed by ERISA.

“Here, in the ERISA context, Darr’s state suit does not prevent the Trustees from fulfilling their duties under ERISA. The findings in support of the injunction rested on ERISA’s mandate that the Plan creates contractual rights and obligations and that the Fund must be administered according to the Plan’s terms notwithstanding contrary state law or federal common law.

Trustees, 2010 WL 850171, at *2 (citing 29 U.S.C. § 1104(a); Kennedy v. Plan Adm’r for DuPont Sav. & Inv. Plan, 555 U.S. 285 (2009)). The district court found that Darr’s state suit would, if successful, require the Fund’s administrator to violate Plan terms shifting attorneys’ fees to beneficiaries. Id. at *3. That the Millers fully reimbursed the Fund, leaving Darr with a common fund claim, was ‘a distinction without a difference’ because in the end, the Fund would still pay his fee (‘now rather than earlier’). Id. These findings, showing Darr as essentially attempting to collaterally attack the Plan’s terms, do not support a finding that Darr’s suit prevents the Trustees from fulfilling their core ERISA duties. The Trustees are not precluded from presenting their federal defense in the state court suit and they may seek damages for whatever injury caused by Darr’s suit if the state court rejects their defenses. Village of Bolingbrook, 864 F.2d at 484 (‘When the opportunity to present the federal defense to state court, coupled with the opportunity to receive damages, carries out all federal policies, then § 2283 forbids injunctive remedies.’).

Vacated.

10-1682, 10-1793 & 10-2579 Trustees of the Carpenters’ Health & Welfare Trust Fund of St. Louis v. Darr

Appeals from the United States District Court for the Southern District of Illinois, Herndon, J., Tinder, J.

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