U.S. District Court of Maryland Case Summaries: October 2, 2011 [Daily Record, The (Baltimore, MD)]
| By Daily Record Staff | |
| Proquest LLC |
Insurance Law
Disability benefits
BOTTOM LINE: Where insurer denied disability benefits for depression based on opinion of insured's psychiatric consultant and neglected to consider records and statements from insured's treating physicians and social workers, remand to insurance plan administrator for a full and fair review was appropriate.
CASE: Zhou v.
FACTS: This case arose from the denial of coverage for long-term disability benefits after
On
In
In
Shortly after receiving the denial of appeal notice,
On
Before
The district court denied the parties' cross-motions for summary judgment and remanded Zhou's claim to the plan administrator for a full and fair review.
LAW: In this case, the court was tasked with determining whether, at each juncture where
By contrast, on
However,
Moreover, in denying Zhou's claim,
When, as here, a plan administrator fails to comply with ERISA's procedural guidelines to provide "full and fair review" of a claim for disability benefits, the proper course of action for the court is remand to the plan administrator to provide such review. Weaver v. Phoenix Home Life. Mut. Ins. Co., 990 F.2d 154, 159 (4th Cir.1993). Remand is most appropriate when the plan itself commits the trustees to consider relevant information which they failed to consider. Elliott v.
Accordingly, the parties' cross motions for summary judgment were denied, and Zhou's claim were remanded to
Real Property
Constructive trust
BOTTOM LINE: Summary judgment on plaintiffs' constructive trust claim was proper because plaintiffs' investment funds that were used to purchase a parcel of land were procured by fraud, deceit, and other improper conduct.
CASE: Kim v. Nyce, Civil Action No. 8:09-CV-01572-AW (filed
FACTS: Plaintiffs Eun Kim and others invested in a real estate business,
The proposed investment was described in a Confidential Summary of Offering, dated
On
Plaintiffs filed suit in district court, charging that a constructive trust was created in their favor in Parcel K by defendants Nyce and
The court granted plaintiffs' motion and denied PK-THF's motion.
LAW: Under Maryland law, the doctrine of constructive trust is an equitable remedy, designed to convert the holder of the legal title to property into a trustee for one who in good conscience should reap the benefits of the possession of said property. Jahnigen v. Smith, 795 A.2d 234, 239 (Md.2002). The remedy is available only: (1) when property is acquired by fraud, misrepresentation, or other improper method; or (2) where the circumstances would render it inequitable for the party holding title to retain it, such as unjust enrichment.
In this case, summary judgment on plaintiffs' constructive trust claim was proper because: (1) plaintiffs' investment funds were used to purchase Parcel K; (2) plaintiffs' funds were procured by fraud, deceit, and other improper conduct; and (3) given that plaintiffs' funds supported the creation of PK-THF and its ownership of Parcel K, it would be unjust for PK-THF to retain the benefit. Parties requesting the imposition of a constructive trust must be able to trace their funds to the property upon which the trust is to be impressed. Bregman, Berbert & Schwartz, L. C.C. v.
Likewise, plaintiffs' investment funds were procured by fraud, deceit, and other improper conduct. On
Finally, because plaintiffs' fraudulently procured investment funds supported the creation of PK-THF and its ownership of Parcel K, it would be unjust for PK-THF to retain the benefit. While PK- THF itself played no role in raising funds from investors, PK-THF came into existence and received Parcel K, its only relevant asset, as part of the property sales agreement Nyce entered into as manager of
Accordingly, the plaintiffs' motion for summary judgment as to their constructive trust claim was granted, and defendants' motion for summary judgment was denied.
COMMENTARY: PK-THF contended that plaintiffs' constructive trust claim was barred by res judicata because plaintiffs failed to argue during the bankruptcy case that they, rather than PK-THF, were the true owners of Parcel K. The doctrine of res judicata bars successive attempts to re-litigate the same cause of action between the same parties, as well as any other claim or issue that could have been raised in the earlier action. Meekins v. United Transp. Union, 946 F.2d 1054, 1057 (4th Cir.1991). Res judicata applies when there is: (1) a final judgment on the merits in a prior suit; (2) an identity of the cause of action in both the earlier and the later suit; and (3) an identity of parties or their privies in the two suits. Pueschel v.
Claims are part of the same cause of action for res judicata purposes when they arise out of the same transaction or series of transactions. Anyanwutaku v. Fleet Mortg.
PRACTICE TIPS: A member of an LLC has no interest in property owned by the LLC. As such, a claim against an LLC member is not legally considered an indirect or a direct claim against the LLC.
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