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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Laflamme v. Carpenters Local 370 Pension Plan

Plaintiff Michael LaFlamme initiated a class action against the Carpenters Local #370 Pension Plan and its Board of Trustees, alleging violations of the Employee Retirement Income Security Act (ERISA) concerning the plan's 'freezing rule' for benefit accrual after a 'break in service.' LaFlamme sought a judicial declaration that this rule contravenes ERISA's minimum accrual standards, along with a reformation of the pension plan and recalculation of benefits for all affected class members. The court, presided over by District Judge Hurd, evaluated the motion for class certification under Federal Rule of Civil Procedure 23(a) and (b), finding that the requirements of numerosity, commonality, typicality, and adequacy of representation were met. Consequently, the motion for class certification was granted, establishing a class comprised of all plan participants, active or retired, who experienced a service break resulting in frozen benefit accrual rates. The decision also outlined procedures for providing notice to the newly certified class members, while deferring detailed adjudication of defenses like statute of limitations and exhaustion of remedies to later dispositive motions.

ERISAPension BenefitsClass ActionBenefit AccrualFreezing RuleBreaks in ServiceClass CertificationRule 23(a)Rule 23(b)Federal Civil Procedure
References
49
Case No. 81 Civ. 3958 (KTD)
Regular Panel Decision
Sep 16, 1982

In Re Pension Plan for Emp. of Broadway Maint.

This case involves a dispute between the Pension Benefit Guaranty Corporation (PBGC) and the bankrupt Broadway Maintenance Corporation over the termination date of Broadway's employee pension plan. The PBGC initiated the lawsuit to be appointed statutory trustee, declare the plan terminated, and sought a termination date of March 26, 1981, while Broadway argued for a retroactive date prior to December 31, 1979. Judge Kevin Thomas Duffy acknowledged the appointment of the PBGC as trustee and the plan's termination, with the sole issue being the precise termination date. After considering the interests of the participants, the PBGC, and Broadway, and applying legal precedent, the court ultimately set December 5, 1980, as the earliest valid termination date. This date was chosen because it marked when the PBGC filed its original Proofs of Claim, signaling its clear intent to terminate the plan.

ERISAPension Plan TerminationEmployee BenefitsBankruptcyPBGCStatutory TrusteeRetroactive Termination DateJudicial TerminationParticipant InterestsFinancial Distress
References
3
Case No. MISSING
Regular Panel Decision

Pig Newton, Inc. v. Boards of Directors of the Motion Picture Industry Pension Plan

Plaintiff Pig Newton, Inc. commenced an action against the Boards of Directors of the Motion Picture Industry Pension Plan, Health Plan, and Individual Account Plan, seeking a declaration that certain provisions of the Plans’ Trust Agreements were invalid and unenforceable. The Defendants counterclaimed for delinquent contributions under ERISA. The core dispute revolved around "Controlling Employee Provisions" in the Trust Agreements, which obligated employers to contribute for Controlling Employees for a specified number of hours and weeks regardless of actual hours worked. Pig Newton argued these provisions were invalid, not properly incorporated, or conflicted with collective bargaining agreements (CBAs). The Court, applying federal common law and an arbitrary and capricious standard of review for the Directors' interpretation, found the provisions valid, properly incorporated, and not in conflict with the CBAs, concluding that Szekely (Pig Newton's sole owner) qualified as a Controlling Employee. Consequently, the Court denied Plaintiff's motion for summary judgment and granted Defendants' cross-motion for summary judgment, dismissing Plaintiff's complaint and awarding Defendants the sought-after contributions, interest, auditors’ fees, and liquidated damages.

ERISAMultiemployer PlanPension PlanHealth PlanDeclaratory JudgmentSummary JudgmentTrust AgreementsCollective Bargaining AgreementsControlling Employee ProvisionsDelinquent Contributions
References
44
Case No. MISSING
Regular Panel Decision

Jeffries v. Pension Trust Fund of the Pension, Hospitalization & Benefit Plan of the Electrical Industry

Plaintiff Claude Jeffries, a retired electrician, sued the Pension Trust Fund of the Electrical Industry under ERISA, seeking to include pension credits from 1969-1975 in his current benefits. He alleged the Plan should have declared a partial termination during a 1975-1979 New York recession, which would have vested his benefits. The defendant moved to dismiss the complaint, arguing lack of standing and statute of limitations, while plaintiff moved for class certification for similarly affected members. The court denied the defendant's motion to dismiss the claim for benefits, finding it timely, but granted dismissal for the breach of fiduciary duty claim as time-barred. The plaintiff's motion for class certification was denied due to insufficient evidence for numerosity, with leave to refile after discovery.

ERISAPension BenefitsClass CertificationMotion to DismissStatute of LimitationsFiduciary DutyPartial TerminationBenefit ForfeitureUnemploymentLabor Union
References
15
Case No. 02 Civ.0032 VM
Regular Panel Decision
Jan 21, 2004

Campanella v. MASON TENDERS'DIST. COUNCIL PENSION

The Campanella brothers, retired participants, sued the Mason Tenders' District Council Pension Plan and its Board of Trustees, alleging multiple ERISA violations regarding pension benefit accrual, vesting standards, and credit for workers' compensation. They challenged the Plan's accrual ranges, anti-backloading provisions, and the policy regarding service credit during disability. The defendants filed cross-motions for summary judgment. The court denied the plaintiffs' motion and granted the defendants' motion, finding that the Plan adhered to ERISA requirements on all substantive points, including minimum accrual standards and vesting. Additionally, claims for interest on delayed benefits and penalties against the Trustees for document production were denied, with the court concluding that no unreasonable delay or bad faith was demonstrated.

ERISAPension BenefitsDisability PensionAccrued BenefitsVesting StandardsStatute of LimitationsSummary JudgmentWorkers' CompensationFiduciary DutyPlan Administration
References
38
Case No. MISSING
Regular Panel Decision
Aug 02, 2013

National Integrated Group Pension Plan v. Dunhill Food Equipment Corp.

This case, filed under ERISA, involves the National Integrated Group Pension Plan and its Board of Trustees (Plaintiffs) seeking to collect withdrawal liability from Dunhill Food Equipment, Esquire Mechanical, Geoffrey Thaw, Sanford Associates, and Custom Stainless (Defendants). The core dispute revolved around whether the non-Dunhill defendants were part of a commonly controlled group at the time of Dunhill's withdrawal from the pension plan, and whether Geoffrey Thaw could be held personally liable through veil piercing. The court ruled that Dunhill, Esquire, and Thaw were jointly and severally liable for the withdrawal liability, attorney's fees, costs, interest, and liquidated damages, finding Thaw's complete domination and misuse of corporate funds justified piercing the corporate veil. However, the claims against Sanford and Custom Stainless were dismissed, as they were determined to have effectively dissolved prior to the withdrawal date, thus not being members of the controlled group.

ERISA LitigationMPPAA LiabilityPension WithdrawalCorporate Veil PiercingSummary Judgment MotionControlled Group LiabilityCorporate DissolutionPersonal LiabilityEmployee Benefits LawFiduciary Breach
References
48
Case No. 11 CV 1471
Regular Panel Decision

Martinez v. Bakery & Confectionery Union & Industry International Pension Fund

The case involves multiple plaintiffs, participants in the Bakery and Confectionery Union and Industry International Pension Fund Pension Plan, who challenged an amendment to the plan. This amendment eliminated the ability for participants no longer in covered employment to "age into" certain early retirement benefits (Plan C and Plan G). Plaintiffs alleged this violated Section 204(g) of ERISA, the anti-cutback rule, which protects accrued benefits. The Court, applying the standard for judgment on the pleadings, found that the Plan C and Plan G benefits are early retirement or retirement-type subsidies and thus accrued benefits under ERISA. Relying on statutory text and precedent like *Ahng v. Allsteel, Inc.*, the Court ruled that the amendment impermissibly cut back accrued benefits for those employees who had met the years of service requirement and could continue to age into their pension benefits even after separation from employment. Consequently, the Court granted the plaintiffs' motions for judgment on the pleadings and denied the defendants' motions.

ERISAPension PlanRetirement BenefitsAnti-cutback RuleEmployee BenefitsJudgment on the PleadingsDefined Benefit PlanEarly RetirementAccrued BenefitsPlan Amendment
References
24
Case No. MISSING
Regular Panel Decision

Meagher, on Behalf of the Pension Plan of the Cement and Concrete Workers District Council Pension Fund v. Board of Trustees of the Pension Plan of the Cement & Concrete Workers District Pension Fund

Plaintiff Meagher previously sued the Cement and Concrete Workers District Counsel Pension Fund and Welfare Fund in 'Action One' for denied pension benefits under ERISA, which was dismissed. Meagher filed a Rule 60(b) motion in Action One, raising 'substantially the same claims' as the current action ('Action Two'), which was also denied. Subsequently, Meagher filed 'Action Two' against the Plan's Trustees, alleging breach of fiduciary duties and ERISA violations regarding pension plan provisions, specifically a 'break in employment' rule impacting vested participants. Defendants moved to dismiss Action Two based on res judicata and collateral estoppel, arguing the issues were, or should have been, litigated in Action One. The Court granted the motion to dismiss, finding an identity of both parties and issues between Action One and Action Two, concluding that res judicata bars the current action.

Res JudicataCollateral EstoppelERISAPension BenefitsFiduciary DutyMotion to DismissRule 12(b)(6)Rule 60(b)Break in ServiceIdentity of Parties
References
98
Case No. MISSING
Regular Panel Decision
Sep 14, 1989

Kinek v. Gulf & Western, Inc.

The Kinek plaintiffs and Pension Benefit Guaranty Corporation (PBGC) sued Gulf & Western, Inc. (G&W) and its pension plan for alleged violations of a collectively-bargained pension agreement and ERISA, stemming from a 'spin-off' where G&W transferred assets and liabilities to Horsehead Industries' pension plan. Plaintiffs argued G&W failed to fully fund vested pension benefits upon this transfer, as contractually required by the G&W Plan's sections 3.1 and 10.2. The court confirmed plaintiffs' standing and applied a de novo standard of review. It ruled that the G&W Plan's provisions, when read together, obligated G&W to provide full funding for vested benefits during an asset transfer. Consequently, the court denied G&W's motion for summary judgment and granted the Kinek plaintiffs' cross-motion for partial summary judgment, holding G&W liable.

ERISALMRAPension PlanEmployee BenefitsSummary JudgmentContract DisputePension FundingAsset TransferSpin-offVested Benefits
References
0
Case No. MISSING
Regular Panel Decision

Seitz ex rel. Pension Plan of the Brewery Workers Pension Fund v. Board of Trustees

Plaintiffs David A Seitz, Thomas Rocco, and Dorothy Casey filed a suit against The Board of Trustees of the Pension Plan of The New York State Teamsters Conference Pension and Retirement Fund. They seek pension benefits, declaratory judgment, and injunctive relief, claiming entitlement under a 1973 Merger Agreement between the Brewery Workers Pension Fund and the Teamsters Plan. The core of their claim revolves around the effective date of the Merger Agreement, arguing for an earlier date to qualify for better benefits. The Defendant moved to dismiss the suit due to improper venue or, alternatively, to transfer it to the United States District Court for the Northern District of New York. The Court, after reviewing ERISA venue provisions and minimum contacts tests, found that the Southern District was not the proper venue and granted the Defendant's motion to transfer the case to the Northern District of New York.

Pension BenefitsERISAVenue TransferMinimum ContactsForum SelectionBrewery Workers Pension FundTeamsters Conference Pension and Retirement FundDeclaratory JudgmentInjunctive ReliefMerger Agreement
References
6
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