Houston v. Teamsters Local 210
Pro se plaintiffs, including Houston, filed a lawsuit against an ERISA-regulated fund seeking severance pay. They argued they were entitled to benefits because their termination occurred 'within one year of' their employer ceasing operations, interpreting the phrase to include the period before cessation. The defendants contended this phrase referred only to the period after cessation and also argued that all plaintiffs, except Houston, failed to exhaust administrative remedies. The court granted summary judgment to the defendants, ruling that the non-Houston plaintiffs failed to exhaust remedies. For Houston's claim, the court found the plan language unambiguously supported the defendants' prospective interpretation of the 'within one year of' clause. Alternatively, even if ambiguous, the plan granted the defendants discretionary authority, and their consistent interpretation was deemed rational and not arbitrary or capricious.