Price v. Bd. of Trustees of the Indiana Laborer's Pension Fund, 09-3897

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.


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:

• Read the Sixth Circuit's Full Decision in Price v. Bd. of Trustees of the Indiana Laborer's Pension Fund, 09-3897