Lois Gibson v. The Prudential Insurance Company of America

Appellant, Gibson was denied disability benefits in 1984 under a self-funded disability benefit plan (“the Plan”) established by her employer. She sued her employer and Prudential Insurance Co. for breach of contract and duty of good faith and fair dealing. Summary judgment was entered in favor of Prudential on the grounds that ERISA preempted Gibson’s claims and Prudential could not be sued under ERISA. Four years later Gibson filed another complaint against Prudential and various doctors and services alleging that they had used an improper disability definition and arranged and participated in a sham medical examination in order to deny her benefits in 1984. The district court granted summary judgment in favor of the defendants because ERISA preempted Gibson’s claims and the defendants were not proper parties under ERISA. Gibson now appeals the summary judgment and we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

Gibson applied for and was denied disability benefits under a self-funded long-term disability benefit plan (“Plan”) established by her employer, TRW Inc. Prudential served as the Plan’s initial claims-handling agent. As an administrator Prudential handled the initial…