E. D. Hayden v. texas-u.s. Chemical Company

681 F.2d 1053, 3 Employee Benefits Cas. (BNA) 2178, 1982 U.S. App. LEXIS 16774
CourtCourt of Appeals for the Fifth Circuit
DecidedAugust 6, 1982
Docket81-2248
StatusPublished
Cited by7 cases

This text of 681 F.2d 1053 (E. D. Hayden v. texas-u.s. Chemical Company) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
E. D. Hayden v. texas-u.s. Chemical Company, 681 F.2d 1053, 3 Employee Benefits Cas. (BNA) 2178, 1982 U.S. App. LEXIS 16774 (5th Cir. 1982).

Opinion

JOHNSON, Circuit Judge:

Texas-U.S. Chemical Company seeks a reversal of the judgment entered in favor of its former employee, E.D. Hayden, on his claim for benefits under the company’s permanent and total disability benefit plan. The judgment must be vacated, but for reasons other than those pressed by the company: it is not possible to discern the basis for the judgment in the findings of fact and conclusions of law set forth by the district court. We remand for reopening of proceedings and reconsideration of Hayden’s claim.

I.

In September 1967 Hayden took a job as a laborer in Texas-U.S. Chemical’s Port Neches, Texas rubber manufacturing plant. Hayden was hired over the objections of company physicians: his pre-employment physical examination disclosed an abnormality in the vertebral structure of his lower back which created a predisposition to serious injury from the strains associated with hard manual labor. Hayden sustained several such injuries in the course of his employment with Texas-U.S. Chemical; because of those injuries, his condition worsened into lumbar disk syndrome aggravated by secondary arthritis. He refused, however, to undergo the surgery recommended by company and private physicians, out of a fear that unsuccessful surgery would leave him disabled.

Hayden was laid off in January 1975 as a result of a general reduction in force. In May 1975, he underwent the first of what would become a series of corrective operations. Notice to Texas-U.S. Chemical of his surgery resulted in a change of his employment status from “laid off” to “medical leave of absence.” Hayden remained in that status until he was terminated for medical reasons in June 1978.

In the fall of 1978, Hayden applied for benefits under the company’s Permanent and Total Disability Plan (the Plan). 1 Hayden’s claim for benefits was denied on the grounds that because his disability occurred while he was in layoff, rather than active, status, and because he had in any case failed to show his disability to be permanent, he had failed to satisfy the eligibility requirements set out in the Plan.

Hayden subsequently initiated legal action charging Texas-U.S. Chemical with breach of contract through a denial of benefits, in contravention of the terms of the collective bargaining agreement. The suit proceeded as one governed wholly by Texas law 2 until the day of trial, when Hayden *1055 first raised his claim to relief under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. § 1001 et seq. The company strenuously objected to Hayden’s interjection of a federal ground for relief, and for sound reason: its defense rested in large measure on the deference accorded private employment agreements under Texas law.

Texas-U.S. Chemical’s first line of defense was drawn from Art. V ¶ 13 of the Plan, which states that

This Plan is entirely voluntary on the part of the Company. An employee acquires neither a vested nor a contractual right hereunder ....

Joint Exhibit at DP-7. The company interpreted this provision to mean that its payment of benefits under the Plan was wholly discretionary, and pointed to Texas cases holding that “benevolent claims” could not be made legally enforceable in the face of contract provisions expressly denying contractual liability therefore. Parrott v. Brotherhood of Railroad Trainmen, 85 S.W.2d 306 (Tex.Civ.App.—Texarkana 1935, writ ref’d n.r.e.); Rieden v. Brotherhood of Railroad Trainmen, 184 S.W. 689 (Tex.Civ.App.—San Antonio 1916, writ ref’d n.r.e.).

The company’s fall-back argument also relied on the limited degree of regulation imposed by Texas law on employee benefit plans. Art. II ¶¶ 1 and 3 3 and Art. V ¶ 1 4 of the Plan placed authority to determine eligibility for benefits in Texas-U.S. Chemical alone; Art. III ¶ 1(b) disallowed benefits to covered employees whose disabilities occurred while laid off. 5 Under Texas law, determinations of benefit eligibility made under such provisions are “not subject to attack in the courts in the absence of a showing of fraud or bad faith,” Long v. Southwestern Bell Telephone Co., 442 S.W.2d 462, 464 (Tex.Civ.App.—San Antonio 1969, writ ref’d n.r.e.); accord, Marsh v. Greyhound Lines, Inc., 488 F.2d 278, 280 (5th Cir. 1974) (applying Texas law). The company claimed that the abundance of evidence in support of its decision conclusively eliminated the possibility that its refusal to pay Hayden’s claim was motivated by either fraud or bad faith. 6

*1056 The case was tried without a jury. Hayden’s post-trial brief more clearly set out his theories of the company’s liability under ERISA; the company continued to claim that Texas law alone could be applied. The district court failed to resolve this dispute in rendering judgment. Although it concluded as a matter of law that

The Permanent and Total Disability Plan of Defendant is a welfare benefit plan as defined in the Employee Retirement Income Security Act of 1974 (ERI-SA), Section 1002. As a welfare benefit plan, the plan administrators and fiduciaries are subject to the reporting and disclosure requirements, the fiduciary responsibilities and the plan administration and enforcement obligations provided for by ERISA.

Record Vol. I at 179, and based its award of attorneys’ fees to Hayden in part on ERISA’s provision for such an award, ERISA § 502(g), 29 U.S.C. § 1132(g), it made no finding that Texas-U.S. Chemical’s denial of benefits to Hayden violated any provision of ERISA. Judgment rested instead on an unsupported, conelusory factual finding that, though the Plan could be terminated unilaterally by the company, and though it specifically denied the existence of contractual claims to benefits, a “right to benefits under the plan did accrue [to Hayden] while an employee of [Texas-U.S. Chemical],” id. at 177, and the denial of benefits was in bad faith, id. at 178. Hayden was awarded damages and attorneys fees in excess of $30,000.

Texas-U.S. Chemical appeals, contending the district court’s decision that Hayden had an enforceable claim to benefits to be without basis in law, and the conclusion that the refusal to pay was in bad faith to be without basis in fact. Hayden argues that the award should be upheld by identification of an ERISA-granted right to those benefits and a finding that that right was abridged.

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681 F.2d 1053, 3 Employee Benefits Cas. (BNA) 2178, 1982 U.S. App. LEXIS 16774, Counsel Stack Legal Research, https://law.counselstack.com/opinion/e-d-hayden-v-texas-us-chemical-company-ca5-1982.