The U.S. District Court for the District of Minnesota recently held that a union welfare benefit trust fund breached the terms of its health plan when it terminated the plaintiff’s coverage based on its erroneous and unreasonable interpretation of Minnesota law. The plaintiff in this case was born a male but later changed gender through sex-reassignment surgery. The plaintiff legally changed her name and gender on her birth certificate and later married. Following the marriage, the plaintiff’s husband enrolled her as his spouse and provided the plan with a copy of the marriage certificate. However, once the fund became aware of the plaintiff’s history, the fund denied her eligibility in the health plan, claiming that in Minnesota, a lawful marriage may be contracted only between persons of the opposite sex and that, despite the amended birth certificate, the plaintiff’s marriage was not recognized under Minnesota law.
The district court held that the fund’s decision to deny plan benefits “was not only wrong … it was a flagrant violation of its duty.” The district court ruled that the fund erred when it terminated the plaintiff’s participation as an eligible family dependent and ordered that the plaintiff be reinstated as a participant. (Radtke v. Miscellaneous Drivers & Helpers Union Local #638 Health, Welfare, Eye & Dental Fund, D. Minn. 2012)