Justia ERISA Opinion Summaries

A class of retirees who had worked under a collective bargaining agreement and their survivors and dependents obtained monetary damages and declaratory and injunctive relief requiring that defendants provide vested lifetime healthcare benefits to the class members depending on the relevant date of retirement (Employee Retirement Income Security Act of 1974, 29 U.S.C. 1132(a)(1)(B); Labor-Management Relations Act, 29 U.S.C. 185). The Sixth Circuit affirmed, holding that defendant Newell Window is bound as a successor liable under earlier collective bargaining agreements to which it was not a party; that members of the plaintiff class had vested rights to company-paid health insurance and/or Medicare Part B premium reimbursements; and that the claims were not barred by the applicable six-year statute of limitations. View "Bender v. Newell Window Furnishings, Inc." on Justia Law

Plaintiffs are 225 current or former employees of steel mills that have changed ownership many times. Calculation of retirement benefits changed with the changes in ownership. The employees claim that their union, employer, and plan administrator violated the Employee Retirement Income Security Act, 29 U.S.C. 1001-1461, and Ohio common law by intentionally misleading them regarding how pension benefits would be calculated, inducing some to retire early. The district court dismissed, concluding that certain ERISA claims were time-barred, that the others failed to state a claim for relief, and that the common-law claims were preempted by federal law. The Sixth Circuit affirmed. The district court properly applied a three-year limitations period to promises allegedly made in 2003. Plaintiffs did not adequately allege fraud underlying breach of fiduciary duty, nor did they establish that the union was a fiduciary. The court rejected a variety of equitable theories. View "Cataldo v. U.S. Steel Corp." on Justia Law

Northwest and the Pilots Association filed a complaint seeking a declaratory judgment that their post-bankruptcy retirement benefit plan (MP3) complied with the Employment Retirement Income Security Act (ERISA), 29 U.S.C. 1001-1461. Appellants (older Pilots) counterclaimed arguing that the MP3 retirement benefit plan violated ERISA, the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-634, and several state laws prohibiting age discrimination. Under the MP3, the contributions of all of the pilots were based on their protected final average earnings, which could not be calculated without the use of age. However, that did not mean that the older Pilots' contributions have been reduced because of their age. There were several factors in the MP3 that could reduce an older pilots' projected final average earnings. While promotions and pay increases were correlated with age, they were analytically distinct and therefore not reductions in contributions because of age. Service ration and the frozen Pension Plan offset also both contributed to potential differences in contribution. Finally, the court rejected older Pilots' argument that the district court improperly disregarded the declaration of their expert witness. Therefore, the court held that the MP3 did not reduce the older Pilots' benefits because of age and therefore affirmed the judgment of the district court. View "Northwest Airlines, Inc., et al. v. Phillips, et al." on Justia Law

The collective bargaining agreement was scheduled to expire. During negotiations, the union disclaimed representation of the company's employees and terminated the collective bargaining process. The company then withdrew from the multiemployer pension plan. The pension fund imposed withdrawal liability and assessed $57,291.50, 29 U.S.C. 1399. The company demanded indemnification from the union pursuant to the collective bargaining agreement, which stated: "The Union shall indemnify the Company for any contingent liability which may be imposed under the Multiemployer Pension Plan Amendments Act of 1980." The district court concluded that an arbitration provision was enforceable. The arbitrator ordered the union to pay. The district court upheld the award. The Sixth Circuit affirmed, rejecting an argument that it would violate public policy for a union to indemnify an employer for any contingent liability to a pension plan established under the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1381-1461. View "Shelter Distrib., Inc. v. Gen. Drivers, Warehousemen & Helpers Union Local No. 89" on Justia Law

Plaintiffs brought a class action against their former employer, Siemens, and its retirement plans, claiming violation of the Employee Retirement Income Security Act in refusing to provide permanent job separation (PJS) pension benefits when Siemens terminated their employment. The Third Circuit reversed in part and directed entry of judgment in favor of Siemens on all issues. By their plain terms, the Siemens plans do not provide for PJS benefits. Siemens did not establish an ERISA section 204 "transition" plan by virtue of 13-day arrangement in 1998 that was part of Siemens' purchase of a business unit from Westinghouse, nor was Siemens obligated to provide PJS benefits under section 208, based on the purchase from Westinghouse. View "Shaver v. Siemens Corp." on Justia Law

The employer sought an early withdrawal from its obligation to make pension contributions to a multiemployer pension fund; it entered into a new collective bargaining agreement, six weeks before expiration of the existing agreement, that abrogated its obligation to make payments to the fund. The fund sued under the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1145. The district court entered summary judgment in favor of the fund. The Seventh Circuit affirmed, rejecting an argument that the agreement was ambiguous in providing that the employer could not “prospectively” change its obligation.View "Cent. States SE & SW Areas Pension Fund v. Waste Mgmt of MI, Inc." on Justia Law

In this case, the district court found that plaintiff's claims against defendant were preempted by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., because they arose under defendant's Pension Plan (Plan) and not separately and independently out of plaintiff's written employment agreement (Agreement). On appeal, plaintiff argued that the additional benefits he sought were based on a promise separate and independent from the Plan. The court held that the district court properly denied plaintiff's motion to remand the case to state court because plaintiff's state law claims were preempted by ERISA where the Agreement merely described the benefits plaintiff would receive as a Plan member and it made no promises of benefits separate and independent from the benefits under the Plan. The suit was properly removed to federal court, the district court had federal jurisdiction over the case, and remand to state court was not warranted. The district court properly dismissed plaintiff's action for failure to state a plausible claim. Finally, the court considered plaintiff's remaining arguments and concluded that they were without merit. Accordingly, the court affirmed the judgment of the district court. View "Arditi v. Lighthouse Int'l" on Justia Law

Plaintiff appealed the district court's grant of summary judgment dismissing her claims against her former employer for defamation; breach of a unilateral contract to pay a performance bonus; failure to timely pay wages after discharge in violation of Minn. Stat. 181.13(a); age discrimination; and interference with her rights to employee benefits in violation of section 510 of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1140, and the court's denial of her motion to continue the summary judgment proceedings. The court agreed with the district court that the employer was entitled to the qualified privilege as a matter of law for plaintiff's defamation claims. The court affirmed the district court's dismissal of the breach of contract and unpaid wages claims because all the employer's documents clearly stated that the awarding of bonuses was discretionary. The court further held that the district court properly granted summary judgment dismissing plaintiff's age discrimination claim where plaintiff failed to show that either of her replacements were "sufficiently younger" or that there was a material question of fact regarding pretext; the district court correctly concluded that plaintiff failed to establish a prima facie case of employee benefit plan interference under section 510 of ERISA; and the district court did not abuse its discretion in denying her motion for continuance. View "Chambers v. The Travelers Companies, Inc." on Justia Law

Abbott created Hospira for its Hospital Products Division. Before the spin-off, HPD employees had access to Abbott's pension plan. Hospira did not offer a pension plan. The spin-off included reciprocal two-year no-hire policies. When HPD employees became Hospira employees, non-vested pension rights in the Abbott plan were eliminated. Retirement-eligible HPD employees were effectively prevented from retiring from Abbott then joining Hospira. A certified class of Hospira employees alleged that violation of the Employee Retirement Income Security Act, 29 U.S.C. 1140, by using the spin and no-hire policy to get rid of pension liability and deter HPD employees from exercising pension benefits before the spin. They alleged that Abbott breached its fiduciary duty by failing to disclose that Hospira would not offer pension benefits. The district court entered judgment for Abbott and Hospira on all counts. The Seventh Circuit affirmed. ERISA claims failed because Abbott and Hospira did not act with the requisite intent to interfere with plaintiffs' pension benefits. The breach-of-fiduciary-duty claim failed because Abbott had nothing to do with the Hospira benefits plan and because Abbott reported truthfully to HPD employees that benefits might change after the spin. View "Nauman v. Abbott Labs., Inc." on Justia Law

This appeal arose from the district court's order dismissing plaintiffs' claim for lack of subject matter jurisdiction due to the Railway Labor Act's (RLA), 45 U.S.C. 151, 181, exclusive and mandatory dispute resolution process that applied to plaintiffs' claims. Plaintiffs argue that the RLA did not apply to them because they were no longer "employees" as contemplated by the RLA. Alternatively, plaintiffs argued that even if the RLA applied to them as former employees, they complied with the terms of their Collective Bargaining Agreement (CBA), which allowed them to bring an action in federal district court pursuant to section 501(a)(1)(B) of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that plaintiffs were employees under the RLA pursuant to Supreme Court precedent. In the alternative, plaintiffs were explicitly looking for a "contracted-for" judicial remedy following an adverse RLA-established Retirement Board ruling without showing any of the narrow exceptions to RLA exclusivity. Therefore, the court declined to depart from established precedent preventing parties from creating federal court jurisdiction where there was none. Accordingly, the judgment was affirmed. View "Ballew, et al. v. Continental Airlines, Inc., et al." on Justia Law