Crooker v. Anheuser-Busch

2007 DNH 069
CourtDistrict Court, D. New Hampshire
DecidedMay 29, 2007
Docket05-CV-008-JD
StatusPublished

This text of 2007 DNH 069 (Crooker v. Anheuser-Busch) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crooker v. Anheuser-Busch, 2007 DNH 069 (D.N.H. 2007).

Opinion

Crooker v . Anheuser-Busch 05-CV-008-JD 5/29/07

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

John R. Crooker

v. Civil N o . 05-cv-008-JD Opinion N o . 2007 DNH 069 Anheuser-Busch, Inc.

O R D E R

In his first claim under the Employee Retirement Income

Security Act ("ERISA"), John R. Crooker seeks retiree medical

benefits from his former employer, Anheuser-Busch, Inc. ("AB").

AB denied his claim for benefits, concluding that he was

ineligible due to his age and insufficient years of creditable

service with AB when he ceased active work. Crooker and AB have

filed a joint statement of material facts and each has filed a

motion for judgment on the administrative record as to Crooker's

first claim.

Background

Crooker began his employment with AB at the Merrimack, New

Hampshire, brewery in 1971. He became a member of the

International Brotherhood of Teamsters, Chauffeurs, Warehousemen

and Helpers of America, Local Union #633, at the same time. On February 2 7 , 1997, Crooker was injured at work. He was fifty-one

years old at the time of his injury.

Because of his injury, Crooker stopped working on October

2 5 , 1998, and began receiving workers' compensation benefits. At

that time, Crooker had accrued eight years and five and one-half

months of continuous employment with AB since his forty-fifth birthday. Crooker was maintained on the AB payroll records with

contractual wage increase information until September 1 8 , 2002,

when he entered into a Severance Agreement with AB to settle his

workers' compensation claim. As part of that agreement, Crooker

resigned from employment at AB as of September 1 8 , 2002.

As a member of Local Union #633, the terms and conditions of

Crooker's employment at AB were governed by a collective

bargaining agreement (the " C B A " ) , the 1998-2004 Plant Agreement

Between AB and the Brewery and Soft Drink Workers Conference, U.S.A. and Canada and Local Union 633 Affiliated with the

International Brotherhood of Teamsters, Chauffeurs, Warehousemen

and Helpers of America. AB also provided insurance benefits

through the Group Insurance Plan for Certain Employees of

Anheuser-Busch Companies, Inc., which includes the Information

Sheet for Early Retiree Eligibility and the Administrative

Booklet, (the "Plan"). Under the terms of the CBA and the Plan,

2 members of the Union could be eligible for retiree health

benefits based on meeting certain requirements.

Crooker filed suit to receive retiree medical benefits from

A B , who removed the action from state court to this court. In

his third amended complaint, Crooker alleged two ERISA claims,

one under 29 U.S.C. § 1132, seeking medical benefits under the Plan, and a second claim, brought under 29 U.S.C. § 1140,

alleging that AB discharged or discriminated against him to

interfere with his rights under the Plan. The parties agreed to

remand the § 1132 claim to the Plan Administrator for a

redetermination of Crooker's eligibility. The second claim,

brought under § 1140, is stayed pending the outcome on the first

claim.

On March 8 , 2006, the AB Health and Welfare Benefits

Eligibility Appeals Committee denied Crooker's claim for retiree medical benefits because he had not achieved ten years of

credited service. AB determined that the time Crooker was not

working, after October of 1998 but before his employment was

terminated in 2002, was not credited service because he did not

return to active work.

Crooker appealed that decision, arguing that the Committee

improperly interpreted provisions of the summary plan description

and applied non-relevant rules for a leave of absence to his

3 application. He argued that because he remained an AB employee

until 2002, that time should have been credited toward service

for purposes of his eligibility for retiree medical benefits. AB

denied his appeal "due to his not meeting the age and service

requirements for retiree medical coverage at the time of his

separation of employment from Anheuser-Busch . . . . ' Ad. Rec. at 137. The Committee again concluded that because Crooker did

not have a qualifying leave of absence, the time between October

of 1998 and September of 2002 did not count toward credited

service. The Committee also stated: "Contrary to the assertions

you make in your letter of April 2 0 , 2006, Anheuser-Busch

administrators and the Committee have consistently interpreted

the Plan Documents's two year limitation and return to active

work requirements as applying to periods of extended absence due

to occupational as well as non-occupational injuries and illnesses." Ad. Rec. at 139. The Committee concluded: Based on the foregoing, it is the Committee's decision that under the retiree medical eligibility rules M r . Crooker's credited service stopped accruing as of October 2 5 , 1998, his last day of active work prior to his leave of absence. At that time M r . Crooker was 53 years old, had 8 years of credited service under the Plan, and was ineligible for retiree medical.

Ad. Rec. at 139.

The parties now seek judgment on the administrative record

as to Crooker's claim for retiree medical benefits brought under

§ 1132.

4 Standard of Review

Anheuser Busch Corporation, AB's parent, is the Plan

Administrator. The parties agree that the Plan gives the

Administrator discretionary authority to interpret its provisions

and to make eligibility determinations. Ordinarily, such

discretionary authority means that the Administrator's decision is reviewed deferentially, under an arbitrary and capricious

standard. See Morales Alejandro v . Med. Card Sys., Inc., ---

F.3d ---, 2007 WL 1430180, at *3 (1st Cir. May 1 6 , 2007).

Crooker argues that because the decision to deny him

benefits was not made by a third-party entity, "heightened

scrutiny of Anheuser-Busch's determination regarding M r .

Crooker's eligibility is warranted due to the inherent conflict

of interest created by Anheuser-Busch's role as both

administrator and employer." P l . Mem. at 5 . Crooker further argues that when a potential conflict of interest exists, the

court should review the challenged interpretation of the plan and

the surrounding circumstances to determine whether the structural

conflict influenced the decision to deny benefits. AB disputes

Crooker's conflict theory and asserts that the deferential

standard applies here.

Recently, a split panel of the First Circuit stated that the

standard applicable in ERISA cases where the plan administrator

is both the decision maker and the payor of benefits should be

5 addressed by that court sitting en banc. Denmark v . Liberty Life

Assurance C o . of Boston, 481 F.3d 1 6 , 19 & 41 (1st Cir. 2007).

As that has not yet occurred, this court applies the "battle-

tested standard of review." Id. at 4 0 .

The First Circuit holds that "the fact that the plan

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