Adams v. Louisiana-Pacific Corp.

284 F. Supp. 2d 331, 31 Employee Benefits Cas. (BNA) 2751, 2003 U.S. Dist. LEXIS 16833, 2003 WL 22208738
CourtDistrict Court, W.D. North Carolina
DecidedJuly 31, 2003
Docket3:01 CV 404-MU
StatusPublished

This text of 284 F. Supp. 2d 331 (Adams v. Louisiana-Pacific Corp.) is published on Counsel Stack Legal Research, covering District Court, W.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adams v. Louisiana-Pacific Corp., 284 F. Supp. 2d 331, 31 Employee Benefits Cas. (BNA) 2751, 2003 U.S. Dist. LEXIS 16833, 2003 WL 22208738 (W.D.N.C. 2003).

Opinion

ORDER

MULLEN, Chief Judge.

THIS MATTER is before the Court on cross Motions for Summary Judgement by Plaintiff William Adams (“Adams”) and Defendants Louisiana Pacific Corporation (“LPC”), ABT Building Products Corporation (“ABTBPC”), ABTco, Inc. (“ABT”), ABT Building Products Supplemental Benefit Plan #2 (“Supplemental Plan”), and the Retirement Committee for the ABT Building Products Corporation Supplemental Benefit Plan # 2 (“Retirement Committee”). All responses have been filed and this matter is ripe for resolution.

I. Background

This case involves a dispute over an interpretation of the terms of a non-qualified employee benefit plan subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), 29 U.S.C. §§ 1001 et seq. The plan at issue, the ABT Building Products Supplemental Benefit Plan # 2, is a “SERP,” or Supplemental Executive Retirement Plan: A non-qualified “top-hat” plan wherein highly paid executives are entitled to greater severance benefits than other employees, i.e. “golden parachutes.” The Supplemental Plan is “self-funded” and “self-administered,” which means that plan benefits are paid in cash directly from the general assets of ABT, and decisions regarding benefit eligibility of employees are handled by ABT’s own personnel (the Retirement Committee) as opposed to a third party administrator. Section 4.1 of the Supplemental Plan sets forth the formula 1 used to determine a participant’s benefits under the plan.

Plaintiff Adams became an ABT employee on October 20, 1992. As an employee he participated in the Retirement Plan, Supplemental Plan, and also received ABT stock options. When ABT merged with LPC on January 19, 1999, the merger agreement provided that holders of options would receive a cash payment in exchange for the surrender of their vested ABT stock options. Adams received cash payments in accordance with this agreement.

As a result of the merger between ABT and LPC, the composition of the Retirement Committee changed from ABT employees to LPC employees. 2 This new Re *335 tirement Committee passed a resolution in October 1999 declaring that payments received by Supplemental Plan participants in exchange for vested stock options did not constitute “Compensation” under the terms of the plan. On March 31, 2000 the Retirement Committee sent Adams a copy of a proposed amendment to the Supplemental Plan allowing Adams to exercise a lump-sum benefit option instead of receiving a paid-up annuity at retirement. Attached to the proposed amendment was a calculation of Adams’s plan benefits which was inconsistent with his understanding of the terms of the Supplemental Plan. 3 Adams did not sign the consent form agreeing to the proposed amendment.

In a letter dated May 2, 2000 Adams made a claim for benefits under the Supplemental Plan which was much greater than the calculation offered by the Retirement Committee in their March 81st letter. On October 30, 2000 the Retirement Committee issued a letter denying Adams’s benefit claims. Adams appealed the decision pursuant to the claims administration procedure specified in the Supplemental Plan in a letter dated December 28, 2000. The Retirement Committee again denied Adams’s benefit claims, whereupon Adams filed this lawsuit.

II. Standard of Review for Summary Judgement Motion

Summary judgement is appropriate when the pleadings, responses to discovery, depositions, and affidavits reveal that no genuine issue of material fact exists and that the moving party is entitled to judgement as a matter of law. FED. R. CIV. P. 56(c). On motion for summary judgment the court reviews the record in a light most favorable to the non moving party. McWilliams v. Metropolitan Life Ins. Co., 172 F.3d 863 (4th Cir.1999).

III. Standard of Review for denial of benefits under ERISA

As an initial matter the parties are in dispute as to the appropriate standard of review for this ERISA action. Defendants argue that this Court should give deference to the Retirement Committee and only disturb their judgement if they abused their discretion in deciding to deny certain benefits to the Plaintiff. Plaintiff contends however, that the appropriate standard is de novo review of the Retirement Committee’s decision.

It is well established that a court reviewing the denial of benefits under ERISA initially must decide whether a benefit plan’s language grants the administrator or fiduciary discretion to determine the claimant’s eligibility for benefits, and if so, whether the administrator acted within the scope of that discretion. Firestone Tire & Rubber Company v. Bruch, 489 U.S. 101, 109 S.Ct. 948, 956, 103 L.Ed.2d 80 (1989). The plan’s intention to confer discretion on the plan administrator or fiduciary must be clear. Gallagher v. Reliance Standard Life Insurance Company, 305 F.3d 264, 269 (4th Cir.2002). If a plan does not clearly grant discretion, the standard of review is de novo. Feder v. Paul Revere Life Ins. Co., 228 F.3d 518, 524 (4th Cir.2000).

Section 5.1 of the Supplemental Plan is clear and unambiguous when it states that the Retirement Committee is to have, “full discretionary authority to determine an individual’s eligibility for bene *336 fits and the amount of benefits payable hereunder and to otherwise interpret and administer the Plan.” Given this clear statement granting discretion to the plan administrator, this Court finds as a rebut-table presumption that the appropriate standard to be applied is a deferential review only for abuse of discretion. Under this standard an administrator’s decision will not be disturbed if it is the result of a principled, deliberate reasoning process and is supported by substantial evidence. Elliott v. Sara Lee Corp., 190 F.3d 601, 605 (4th Cir.1999); Brogan v. Holland, 105 F.3d 158, 161 (4th Cir.1997). However the deference paid by the court to the decision of the administrator may be reduced where the administrator or fiduciary has a conflict of interest. Id. This modified abuse of discretion standard allows the court to reduce the amount of deference normally given to the degree necessary to neutralize any untoward influence resulting from the conflict. Gallagher, 305 F.3d at 269 citing Ellis v. Metropolitan Life Ins. Co., 126 F.3d 228, 233 (4th Cir.1997).

Instead of this modified abuse of discretion standard, Plaintiff cites Goldstein v.

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284 F. Supp. 2d 331, 31 Employee Benefits Cas. (BNA) 2751, 2003 U.S. Dist. LEXIS 16833, 2003 WL 22208738, Counsel Stack Legal Research, https://law.counselstack.com/opinion/adams-v-louisiana-pacific-corp-ncwd-2003.