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Cole v. Trinity Health Corp.

United States Court of Appeals, Eighth Circuit

December 15, 2014

Bonnie Cole, Individually and as Next Friend of P.C., a Minor; Lyle Cole, Individually and as Next Friend of P.C., a Minor, Plaintiffs - Appellants
v.
Trinity Health Corporation, Defendant - Appellee

Submitted September 8, 2014

Page 424

Appeal from United States District Court for the Northern District of Iowa - Ft. Dodge.

Bonnie Cole, Individually and as Next Friend of P.C., a Minor, Lyle Cole, Individually and as Next Friend of P.C., a Minor, Plaintiffs - Appellants: Patrick Thomas Vint, HOPKINS & HUEBNER, Des Moines, IA.

Trinity Health Corporation, Defendant - Appellee: Sarah Elizabeth Crane, Gene R. La Suer, DAVIS & BROWN, Des Moines, IA.

Before BENTON, BEAM, and SHEPHERD, Circuit Judges.

OPINION

Page 425

SHEPHERD, Circuit Judge.

When Bonnie Cole[1] stopped working for Trinity Health Corporation (" Trinity Health" ), the company failed to timely notify the Coles of their right to continuing health care coverage, as it was required to do. The Coles sought statutory damages, which may be awarded in the court's discretion after a violation of this notification requirement, but the district court[2] declined to award damages and granted summary judgment to Trinity Health. We are asked to decide whether this decision was in error. We find no abuse of discretion in the district court's denial of statutory damages and therefore affirm the grant of summary judgment.

I.

When Bonnie was a Trinity Health employee, she enrolled in an employer-sponsored group health plan with Blue Cross Blue Shield of Michigan (" Blue Cross" ), for which Trinity Health served as plan administrator. Lyle and P.C. enrolled as beneficiaries. Bonnie later began a period of leave from Trinity Health, first under the Family and Medical Leave Act of 1993, and then under short-term disability leave. Her short-term disability benefits expired June 8, 2011. When they did, Bonnie requested long-term disability benefits. While it considered this request, Unum, Trinity Health's long-term disability benefits provider, provisionally paid Bonnie's medical care claims under a " Reservation of Rights." On October 18, 2011, however, Unum denied Bonnie's request but chose not to seek repayment of the provisional benefits it had provided.

Bonnie's termination date should have been June 8, 2011, the last day she qualified for benefits and was considered a Trinity Health employee. But because of an error[3] her termination was not processed when Unum denied her long-term disability benefits request. As a result, Bonnie, Lyle, and P.C. continued to receive Blue Cross health insurance benefits well into 2012. Trinity Health finally discovered its error and processed Bonnie's termination in late April and early May 2012. Righting itself, Trinity Health set Bonnie's termination date at June 8, 2011, but deemed her benefits retroactively terminated January 1, 2012. Although Trinity Health's system indicated that on May 8, 2012, the Coles were sent notice that their health care coverage had been terminated, Trinity Health later determined no notice was sent on that date.

The Coles were first alerted to their benefits change on June 1, 2012, when Lyle visited his physician and was told his family no longer had insurance. Bonnie contacted Blue Cross for clarification. On June 8, 2012, Blue Cross notified the Coles their benefits had been terminated effective ...


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