Norstan Incorporated v. Jennifer Lancaster

MEMORANDUM

Jennifer Lancaster, personal representative of the Estate of James Joseph Lancaster (the “Estate”) (collectively, Ms. Lancaster and the Estate are the “Estate Defendants”), filed this interlocutory appeal after the district court granted a preliminary injunction requested by Norstan Inc., an ERISA plan administrator, and Black Box Network Services Employee Health Plan (the “Plan”). The district court’s order enjoined the Estate Defendants from dismissing or accepting settlement of the Estate’s claims against certain medical services providers without the written consent of the Plan, other than for amounts “above and beyond the reasonable value of services and benefits the Plan provided to Lancaster.” Norstan Inc. v. Lancaster, 12-cv-00481-GMS, 2012 WL 3155575 , at *5 (D.Ariz. Aug. 3, 2012). We affirm.

The Estate Defendants argue that the district court had no jurisdiction to issue the injunction and that the Estate is not bound by the ERISA plan documents because the Estate is not a “covered person” under the terms of the ERISA plan. These arguments are without merit.

Whether a party is “covered” under the terms of an ERISA plan “is a substantive element of [the]…