6th Circuit Affirms Dismissal of Ohio National Insurance's Trail Commission Class Action
Several cases around the country remain pending against the insurer after its 2018 decision to stop paying trail commissions to broker-dealers for variable annuities they marketed and serviced.
June 10, 2020 at 05:13 PM
5 minute read
A federal appeals court has affirmed an Ohio judge's dismissal of a putative class action against Ohio National Insurance over the company's decision to stop paying certain kinds of commissions on variable annuities.
The Tuesday opinion agreed that the named plaintiff, a representative for a broker-dealer who sold the annuities, was not a party to the contract between Ohio National and the brokerage firm, and thus had no standing to sue.
The case is one of several in various stages of litigation against Ohio National and related entities over its decision to discontinue payment of trail commissions to brokers and agents who serviced its variable annuities from 2012 through 2018, when it stopped selling them and discontinued the payments.
Thousands of brokers were affected by the decision to end the payments, which were offered to them in lieu of accepting lump-sum commissions when they sold the annuities.
Complaints have been filed around the country asserting that Ohio National breached agreements under which the brokers were guaranteed to receive the commissions until the annuities were surrendered or annuitized—which is when they are converted into fixed, regular payments by the purchaser.
Three such suits were filed in Ohio's Southern District. U.S. District Senior Judge Susan Dlott dismissed two of them in October, and the plaintiffs appealed in both cases.
Tuesday's ruling comes in the case of Stephen Cook, a Texas-based securities representative employed by broker-dealer Triad Advisors.
Triad had a contract with Ohio National under which the insurer would pay annuities to Triad, which in turn paid its representative under a separate agreement.
After Ohio National stopped paying the commissions, Cook filed a class action against the insurer for breach of contract, arguing that he was a "third-party beneficiary" to its agreement with Triad. He also filed a claim for unjust enrichment.
A magistrate judge's report and recommendation agreed that Cook was an "intended" third-party beneficiary but Dlott found otherwise, writing that the selling agreement was solely between Ohio National and Triad. She also found that there was no basis for the unjust enrichment claim.
The appellate opinion affirming Dlott's dismissal was written by Senior Judge Gilbert Merritt with the concurrence of Judges Richard Suhrheinrich and Jeffrey Sutton.
The selling agreement explicitly stated that the commissions were to be paid to Triad, Merritt wrote, and "provided that any compensation paid to the representatives such as plaintiff will be Triad's responsibility.
"The requirement to have a separate contract cuts against any suggestion that the selling agreement was intended to directly benefit representatives like plaintiff," he said.
Because the agreement "unambiguously directs Ohio National to pay commissions to Triad," the opinion said, Cook's claim for unjust enrichment is also without basis under Ohio law.
The second case Dlott dismissed, Browning v. Ohio National Life Insurance, was scheduled for video arguments at the Sixth Circuit next week, but they have been canceled and the case will be decided solely on briefs, according to the appellate docket.
The Ohio National defendants are represented by Marion Little Jr. and Christopher Hogan of Columbus' Zeiger, Tigges & Little. They did not respond to a request for comment Wednesday.
Cook is represented by B. Nathaniel Garrett, James Helmer Jr. and Robert Rice of Helmer, Martins, Rice & Popham in Cincinnati.
In an email Garrett said the ruling was unfortunate.
"The fact remains that advisors earned commissions by selling Ohio National's variable annuities, and Ohio National decided to unilaterally stop paying those earned commissions," Garrett said. "At a time when many are struggling financially, this ruling forecloses court access and compounds the ongoing harm suffered by affected advisors."
"Advisors were necessary to sell and service the annuities, but are now forced to sit on the sidelines while their entitlement to commissions for all of their hard work is litigated between Ohio National and broker-dealers," he said.
Garrett said his firm is monitoring two related appeals and the third broker-dealer class action in Ohio's Southern District, Veritas Independent Partners LLC v. Ohio National Life Insurance, which remains pending.
"Should the broker-dealers' class action be resolved in their favor, financial advisors should still be entitled to their promised compensation," Garrett said.
A similar case in the Southern District of Texas has been stayed pending the outcome of the Veritas litigation.
Meanwhile, Ohio National settled another case in Texas' Western District and one in Illinois; the insurer continues to fight a Massachusetts judge's order directing a trail commission case there to FINRA arbitration.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllTrump Mulls Big Changes to Banking Regulation, Unsettling the Industry
As AI-Generated Fraud Rises, Financial Companies Face a Long Cybersecurity Battle
After Fining Investment Firms Billions for Lost Text Messages, Regulators Turn Scrutiny to Audio Recordings
FactSet Finds New Legal Chief at Financial Data Rival S&P
Trending Stories
- 1Data Breach Lawsuit Against Byte Federal Among 1,500 Targeting Companies in 2024
- 2Counterfeiters Ride Surge in Tabletop Games’ Popularity, Challenging IP Owners to Keep Up
- 3Health Care Data Breach Class Actions Saw December Surge in NY Courts
- 4Florida Supreme Court Disbars 3, Suspends 11, Reprimands 1 in Final Disciplinary Order of 2024
- 5Chief Justice Roberts Ends Year With Defense Against 'Illegitimate' Attacks on Judiciary
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250