ERISA action challenging pension plan's amendment to limit occupational disability benefits
Price v. Bd. of Trustees of the Indiana Laborer's Pension Fund, 09-3897, concerned a challenge to the district court's grant of plaintiff's motion for summary judgment in plaintiff's suit against his pension plan challenging the denial of his benefits and claiming that the plan amendment to limit the payment of occupational disability benefits to a period of two years violated ERISA because his occupational disability benefits had vested as a matter of law.
Price v. Bd. of Trustees of the Indiana Laborer's Pension Fund, 09-3897, concerned a challenge to the district court's grant of plaintiff's motion for summary judgment in plaintiff's suit against his pension plan challenging the denial of his benefits and claiming that the plan amendment to limit the payment of occupational disability benefits to a period of two years violated ERISA because his occupational disability benefits had vested as a matter of law.
In vacating the judgment, the court remanded the case in concluding that
this case is properly understood under a different framework that does
not include either Yard-Man or Sprague, as case law has not addressed
whether the Yard-Man inference can be appropriately applied outside the
context of retiree health benefits and the benefits at issue in Sprague
were specifically characterized as unilaterally offered benefits and not
bargained-for benefits as present in this case. Further, because the
district court did not review the Board's determination under the
arbitrary and capricious standard, as the plan gives the Board
discretion to interpret its terms, the essence of this case turns on the
reasonableness of the Board's decision.
Related Link:
Related Link:
- Read the Sixth Circuit's Full Decision in Price v. Bd. of Trustees of the Indiana Laborer's Pension Fund, 09-3897
