Post Office Health and Disability plan subject to ERISA
In Graham v. Hartford Life & Accident, the Tenth Circuit held that a health and disability plan provided to US postal employees was not a governmental plan – therefore it was subject to ERISA. The plan was apparently offered through the National Rural Letter Carriers Association, the exclusive bargaining agent for rural letter carriers. Since the plan was governed by ERISA, there was no right to a jury trial. The court affirmed the ruling of the trial court that the denial of benefits was not arbitrary and capricious