Virginia Madonia v. Blue Cross & Blue Shield of Virginia

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that a physician’s status as the corporation’s sole shareholder did not bar him from being an “employee” under ERISA’s definition of the term
• recognizing that owner of corporation could not be sole participant in employee benefit plan, but finding ERISA applied because “MNA’s plan benefitted employees other than Dr. Madonia”
• suggesting that Kwatcher’s holding that an employer cannot also be a participant was also overruled
• stating that “under the statutory definition of an employee welfare benefit plan, employers may easily establish ERISA plans by purchasing insurance for their employees”
• interpreting Nationwide Mutual Ins. Co. v. Darden, 503 U.S. 318, 112 S.Ct. 1344, 117 L.Ed.2d 581 (1992) as contrary to Kwatcher.
• “Disallowing shareholders ... from being plan ‘participants’ would ... frustrate[ ] the statutory purpose of ensuring similar treatment for all claims relating to employee benefit plans.”

Source: CourtListener parenthetical corpus (CC0).