Justia U.S. 2nd Circuit Court of Appeals Opinion Summaries

Plaintiffs sued Metro to recover contributions owed pursuant to the Employer Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1145. Metro challenged the damages award, arguing that the method set forth in the collective bargaining agreement resulted in an impermissibly speculative damages award. The court disagreed and held that the parties were free to agree to an alternative method of calculating damages without offending the requirement that damages be proven with "reasonable certainty." Accordingly, the court affirmed the judgment. View "Cement and Concrete Workers District Council Welfare Fund v. Metro Foundation Contractors" on Justia Law

This appeal and purported class-appeal primarily concerned two issues arising under the Employee Retirement Income Security Act of 1974 (ERISA), 28 U.S.C. 1001 et seq. The first issue was whether trustees of a multi-employer pension fund acted as fiduciaries when they amended the pension plan. The second issue was whether the claims asserted in this case were time-barred. The court concluded that the dismissal of Counts I-V was proper because the trustees were not acting as fiduciaries in amending the Plan, and in reaching that conclusion, the court deemed the contrary rulings of the court in Chambless v. Masters, Mates & Pilots Pension Plan and Siskind v. Sperry Retirement Program, to have been abrogated by subsequent decisions of the Supreme Court. The court also concluded that fact issues remained as to whether Counts VII-IX were properly dismissed as time-barred. View "Janese v. Fay" on Justia Law

The Fund is a multiemployer defined-benefit pension plan. Honerkamp, a New York employer, contributed to the Fund pursuant to collective bargaining agreements with its employees. In 2008, the trustees announced that the Fund was in critical status as defined by the Pension Protection Act of 1996, 29 U.S.C. 1085(b)(2) and began drafting a rehabilitation plan. Because the rehabilitation plan would figure prominently in negotiations between Honerkamp and the union, the parties extended existing agreements. The final rehabilitation plan set forth new schedules of reduced benefits and increased contributions. According to the plan, the Fund was unlikely to emerge from critical status within the statutory 10-year rehabilitation period because employer contribution rates required for that result would exceed amounts that employers would have had to pay to withdraw from the Fund. The trustees therefore designed schedules “to impose approximately the same burden actuarially on employers that a withdrawal from the [Fund] would produce.” Following negotiations, Honerkamp withdrew from the Fund. The trustees sued, arguing that the PPA prevented Honerkamp from withdrawing and required the company to make certain ongoing pension contributions pursuant to the rehabilitation plan. The district court granted summary judgment to Honerkamp. The Second Circuit affirmed. View "Trs. of Local 138 Pension Trust Fund v. F.W. Honerkamp Co. 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.

Plaintiffs appealed from the judgment of the district court dismissing as time-barred their putative class action complaint against their former employer and the employer's pension plan for benefits alleged to be due under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs asserted that the district court erred when it looked past the six-year New York limitations period for contract actions; applied part of the New York regime known as the "borrowing statute," which directed it to Pennsylvania law; and ruled that Pennsylvania's four-year limitations period barred plaintiffs' claims. The court held that in an action for benefits under 29 U.S.C. 1132, the court applied the forums state's statute of limitations, including its borrowing statute. Therefore, the district court was correct in applying New York's borrowing statute and plaintiffs' claims were untimely under Pennsylvania law.

Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)-(3), seeking to recover funds that were erroneously removed from his pension fund account and credited to that of his former wife. The district court entered judgment against the Plan, including the principal amount, accumulated earnings, and pre-judgment interest. On appeal, the Plan argued that enforcement of the judgment was prohibited by the terms of the pension agreement, ERISA's anti-alienation provision, and other provisions of federal and state law. The Plan also argued that the district court's award of accumulated earnings was inconsistent with the court's decision in Dobson v. Hartford Financial Services Group. The court considered all the Plan's arguments and found that none of them warranted reversal of the district court's judgment that the Plan must pay plaintiff what he was due, whether or not it could succeed in recovering the funds that it, through no fault of plaintiff's, erroneously paid to his former wife.

Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)-(3), seeking to recover funds that were erroneously removed from his pension fund account and credited to that of his former wife. The district court entered judgment against defendant in the amount of $1,571,723.73, which included the principal amount, accumulated earnings and pre-judgment interest. On appeal, defendant argued that enforcement of the judgment was prohibited by the terms of the pension agreement, ERISA's anti-alienation provision, and other provisions of federal and state law. Defendant also argued that the district court's award of accumulated earnings was inconsistent with the court's decision in Dobson v. Hartford Financial Services Group, Inc. Applying the appropriate standards of review, the court found defendant's arguments were without merit and affirmed the judgment of the district court.

This appeal and cross-appeal concerned the pension benefits owed to plaintiff, a retired carpenter, and members of a class he purported to represent. Plaintiff asserted that the pension fund was guilty of seven violations of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., and sought declaratory and injunctive relief. The court agreed with the district court that defendants' interpretations of certain plan language was arbitrary and capricious and therefore affirmed the district court's award of summary judgment to plaintiff on his individual claims for miscalculation of pension benefits. The court concluded, however, contrary to the district court, that the six-year statute of limitations applicable to plaintiff's and each other putative class member's ERISA claims began to run when each pensioner knew or should have known that defendants had miscalculated the amount of his pension benefits, and that he was being underpaid as a result. Therefore, the court vacated the district court's judgments certifying the plaintiff class, granting summary judgment to the class, and granting prejudgment interest to the class members. The court remanded for further factfinding with regard to when each putative class member became, or should have become, aware of his alleged injury so as to begin the running of the statute of limitations as applied to him.

Plaintiffs appealed from a decision granting defendants' motion to dismiss plaintiffs' complaints for failure to state a claim upon which relief could be granted. Plaintiffs, participants in two retirement plans offered by defendants, brought suit alleging breach of fiduciary duty under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiff alleged that defendants acted imprudently by including employer stock as an investment option in the retirement plans and that defendants failed to provide adequate and truthful information to participants regarding the status of employer stock. The court held that the facts alleged by plaintiffs were, even if proven, insufficient to establish that defendants abused their discretion by continuing to offer plan participants the opportunity to invest in McGraw-Hill stock. The court also held that plaintiffs have not alleged facts sufficient to prove that defendants made any statements, while acting in a fiduciary capacity, that they knew to be false. Accordingly, the judgment was affirmed.

Plaintiffs, participants in retirement plans offered by defendants and covered by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., appealed from a judgment dismissing their ERISA class action complaint. Plan documents required that a stock fund consisting primarily of Citigroup common stock be offered among the plan's investment options. Plaintiffs argued that because Citigroup stock became an imprudent investment, defendants should have limited plan participants' ability to invest in it. The court held that plan fiduciaries' decision to continue offering participants the opportunity to invest in Citigroup stock should be reviewed for an abuse of discretion and the court found that they did not abuse their discretion here. The court also held that defendants did not have an affirmative duty to disclose to plan participants nonpublic information regarding the expected performance of Citigroup stock and that the complaint did not sufficiently allege that defendants, in their fiduciary capacities, made any knowing misstatements regarding Citigroup stock. Accordingly, the court affirmed the judgment.