
Disability Plan Offered By Nondenominational Christian Ministry Was Not A "Church Plan" That Fell Outside ERISA
In this case, the United States District Court held that a long-term disability plan offered to employees by a Christian ministry was not exempt from the Employee Retirement Income Security Act (ERISA) as a "church plan" where the ministry, which acted primarily as vendor of Bible study products and trained Bible study teachers, did not constitute a "church" under ERISA.
Although it had status as a
nonprofit entity pursuant to the Internal Revenue Code, the nondenominational
ministry was not funded or governed by a specific religious institution, did not
require its employees or board members to be members of any particular Christian
denomination, did not have an established congregation, did not have a clergyman
on staff, and did not conduct religious services on a regular basis. Thus, an
employee's state-law claims arising from the denial of a policy claim were
preempted by ERISA.
Goetz v. Greater
Georgia Life Ins. Co.