No. 20-1444

W. A. Griffin v. Coca-Cola Refreshments USA, Inc., et al.

Lower Court: Eleventh Circuit
Docketed: 2021-04-15
Status: Denied
Type: Paid
Response Waived
Tags: anti-alienation anti-assignment assignment-of-benefits claims-fiduciary erisa fiduciary-duty health-benefits plan-administrator provider-services waiver
Latest Conference: 2021-09-27
Related Cases: 20-1655 (Vide)
Question Presented (from Petition)

Whether the anti-assignment provision in the Coca-Cola Plan apply to W. A. Griffin, MD ("Dr. Griffin"). Anti-assignment and anti-alienation contained in employer sponsored group health benefit plans subject to the Employee Retirement Investment Security Act of 1974 ("ERISA") are usually not applicable to an assignee who is the provider of the services which the plans are maintained to furnish. Dr. Griffin provided health services to Patient J.J., individual covered by the Coca-Cola Refreshments USA, Inc. ("Coca-Cola") employer-sponsored group health benefit plan ("Coca-Cola Plan"), and Patient J.J. executed an assignment to Dr. Griffin that states the assignment is a "direct legal assignment of [Patient J.J.'s] rights and benefits under" the Coca-Cola Plan.

Whether a plan administrator and claims fiduciary can be estopped from asserting, and can waive, an anti-assignment or anti-alienation provision by failing to timely assert the provision. Neither Coca-Cola, as plan administrator of the Coca-Cola Plan, nor United Healthcare Insurance Company ("United"), as claims fiduciary of the Coca-Cola Plan, asserted the application of the Coca-Cola Plan's anti-assignment provision during the process of Dr. Griffin's appeals from underpayment for provided health services.

Whether Patient J.J. assigned to Dr. Griffin the right to sue for breach of fiduciary duties, breach of fiduciary duties, and failure to provide plan documents. On December 21, 2012, Patient J.J. executed an assignment to Dr. Griffin that states the assignment is a "direct legal assignment of [Patient J.J.'s] rights and benefits under" the Coca-Cola Plan.

Whether published Eleventh-Circuit case law that voids assignment of benefits with unambiguous anti-assignment clauses incorporated into the Coca-Cola Plan is legal in Georgia, a state with mandatory provider assignment of benefit legislation.

Question Presented (AI Summary)

Whether the anti-assignment provision in the CocaCola Plan apply to W. A. Griffin, MD (Dr. Griffin)"

Docket Entries

2021-10-04
Petition DENIED.
2021-06-30
DISTRIBUTED for Conference of 9/27/2021.
2021-06-25
Waiver of right of respondent Coca-Cola, et al. to respond filed.
2021-03-29
Petition for a writ of certiorari filed. (Response due May 17, 2021)

Attorneys

Coca-Cola, et al.
Tashwanda Pinchback DixonBalch & Bingham LLP, Respondent
W. A. Griffin
W. A. Griffin — Petitioner