On January 24, 2025, the U.S. District Court for the District of New Jersey dismissed a putative ERISA class action lawsuit against Johnson & Johnson (J&J). The plaintiff alleged that J&J’s health plan fiduciaries mismanaged the self-funded health plan’s prescription drug benefits, claiming excessive costs for premiums and out-of-pocket expenses.

Key Highlights of the Ruling:

– The court found that the plaintiff lacked Article III standing, primarily because her allegations regarding increased costs were deemed speculative. The court stated that claims of paying “too much” for healthcare were insufficient without concrete evidence.

– While the plaintiff did allege she faced higher out-of-pocket costs for specific drugs, the court held that her injuries were not redressable since she had already reached the plan’s out-of-pocket maximum for medical expenses.

– The court did, however, allow a claim regarding the employer’s failure to produce plan documents as required under ERISA section 104(b)(4).

This ruling is considered a victory for employers and a setback for efforts to hold them liable for allegedly excessive health plan fees. It reinforces the need for clear documentation and due diligence in the management of health plans.

The Lewandowski decision aligns with previous rulings, emphasizing that mere assertions of overpayment do not suffice for legal standing. This trend may affect ongoing and future cases involving health plan fee claims. As the landscape of ERISA litigation evolves, we will continue to monitor developments closely. Please feel free to reach out if you have any questions or need further insights on this matter.