Gamache v. Iam National Pension Fund

CourtDistrict Court, District of Columbia
DecidedFebruary 24, 2025
DocketCivil Action No. 2023-1131
StatusPublished

This text of Gamache v. Iam National Pension Fund (Gamache v. Iam National Pension Fund) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gamache v. Iam National Pension Fund, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _________________________________________ ) MICHAEL GAMACHE, ) ) Plaintiff, ) ) v. ) Case No. 23-cv-1131 (APM) ) IAM NATIONAL PENSION FUND, ) ) Defendant. ) _________________________________________ )

MEMORANDUM OPINION

I. INTRODUCTION

Plaintiff Michael Gamache brings this action against Defendant IAM National Pension

Fund (the “Fund”) under the Employee Retirement Income Security Act (“ERISA”), 29 U.S.C.

§ 1001 et seq. Plaintiff alleges that the Fund wrongfully denied him disability pension benefits

after an on-the-job injury. The parties have cross-moved for summary judgment. The court

concludes that it cannot enter judgment fully in favor of either party on the record before it.

Instead, as explained below, the court will deny the Fund’s motion, grant in part and deny in part

Plaintiff’s motion, and remand to the Fund for further proceedings consistent with this opinion.

II. BACKGROUND

A. Factual Background

1. The Disability Pension Policy

The Fund is a qualified “plan,” “pension plan,” and “multiemployer plan” within the

meaning of ERISA. See 29 U.S.C. § 1002(2), (3), (37); see also AR 159. 1 It was set up to provide

pension benefits for employees who are “represented for the purposes of collective bargaining” by

1 The court refers to citations in the Administrative Record as “AR.” It is available in full at ECF No. 9. a union affiliated with the International Association of Machinists and Aerospace Workers.

AR 332. The Fund is jointly administered by a Board of Trustees, which consists of an equal

number of union and employer representatives. AR 371.

This case concerns the terms under which the Fund will pay pension benefits due to

disability. Section 4.8 of the Fund’s National Pension Plan Document (the “Plan”), entitled

“Eligibility for a Disability Pension,” provides that “[a] Covered Employee who has not attained

age 65 shall be entitled to a Disability Pension if he becomes totally and permanently disabled.”

AR 223. There is no dispute that Plaintiff is a “Covered Employee.”

To establish total and permanent disability, a Covered Employee must make a two-part

showing. First, the employee must demonstrate that he is “unable, as a result of bodily injury or

disease, to engage in or perform the normal and customary duties of his occupation or any similar

or related occupation for renumeration or profit[.]” Id. Second, the employee must establish that

“such disability will be permanent and continuous for the remainder of his life.” Id. Whether an

employee is “permanently and totally disabled within the meaning of [the] Plan” rests in the “sole

and absolute discretion” of the Fund’s Trustees. Id. 2 Further, “[t]he Trustees have the sole and

absolute authority, in [their] discretion, to interpret [the] Plan and to determine eligibility for

benefits under [the] Plan.” AR 271.

2. Plaintiff’s Injury and Early Medical Treatment

Plaintiff was hired as a maintenance mechanic for the United Parcel Service in March 1998.

AR 61, 143. The job required Plaintiff to, among other things, “[l]ift, lower, push, pull, leverage

and manipulate equipment and/or packages weighing up to 70 pounds” and “[w]ork at elevated

heights, in enclosed spaces and [on] uneven walk surfaces.” AR 96.

2 The Plan uses “totally and permanently disabled” and “permanently and totally disabled” interchangeably in the section defining eligibility for a disability pension. See AR 223.

2 On February 5, 2020, Plaintiff suffered a workplace injury when he jumped off a conveyor

belt and sprained his right ankle. AR 2, 28. Thereafter, Plaintiff went to the emergency room,

“where he had radiology testing performed of the right ankle, was treated, provided with a splint

and crutches and released the same day.” AR 28. Months later, on June 22, 2020, Dr. Kevin Scott,

an orthopedic surgeon, diagnosed Plaintiff with an anterior talar ligament tear on his right ankle.

AR 2. In August 2020, Plaintiff underwent an ankle arthroscopy and lateral ankle reconstruction

surgery performed by Dr. Kevin Rosas. Id., AR 49. He then attended physical therapy at LaMarco

Physical Therapy from September 22, 2020, until March 16, 2021. AR 16.

Plaintiff was periodically reevaluated by these doctors and facilities. Dr. Scott examined

Plaintiff on November 30, 2020. See AR 2. At that time, Plaintiff reported being unable to “kneel,

squat, run, jump, stand on his [toes] or climb ladders since the accident.” AR 3. Dr. Scott reported

at that time that Plaintiff “can only do a sedentary job with no bending, no prolonged standing and

no climbing, jumping or running.” AR 4. However, Dr. Scott found that Plaintiff’s “prognosis

for return to work is fair.” AR 5.

Dr. Rosas, Plaintiff’s surgeon, saw him on December 2, 2020. AR 49. He noted that

Plaintiff “was unable to return to work” but expected that there would be “some continued

improvement over the next month to 2 months and [Plaintiff] may be able to return to work prior

to a return visit.” Id. Four months later, in March 2021, LaMarco Physical Therapy reported that

Plaintiff “had 30 visits with good progress” but was “still having functional difficulty and

weakness with isolated ankle motions,” resulting in difficulty with “[s]quatting, kneeling, getting

onto [the] floor, [and] walking on uneven ground.” AR 16; see also AR 17 (noting that Plaintiff

“continues to demonstrate significant functional loss especially in terms of his occupation that

requires full strength and stability on elevated levels, ladders, and in tight spaces”).

3 On March 31, 2021, Plaintiff was examined by Dr. Adam Soyer, an orthopedic specialist

hired by the New York State Workers’ Compensation Board to conduct an independent medical

assessment. AR 28–34. Dr. Soyer noted in an April 2021 report that Plaintiff was “not capable of

regular duty work,” but opined that he would “be able to return to pre-injury activities as a

maintenance . . . mechanic in 06/2021.” AR 31.

Dr. Rosas again evaluated Plaintiff in April 2021. He observed that Plaintiff continued to

have ankle mobility limitations and recommended that he continue to work with physical therapy

before pursuing further surgical options. AR 51–52. Dr. Rosas did not opine on Plaintiff’s return

to work at this time.

3. Plaintiff’s Requests for Permanent Disability Benefits

Plaintiff first applied to the Fund for permanent disability benefits in March 2021. AR 20–

26. The Plan provides that “[t]he Trustees, in their sole and absolute discretion, may require or

accept, as sole proof of total and permanent disability, the determination by the Social Security

Administration that the employee is entitled to a Social Security Disability Benefit in connection

with his Old Age and Survivors Insurance coverage.” AR 223. The Fund thus requested that

Plaintiff submit a Notice of Award letter from the Social Security Administration (“SSA”)

indicating the date he was deemed disabled by the agency. See, e.g., AR 53–54. It made that

request four times. Id.; AR 58–60. Plaintiff never provided an SSA letter, so the Fund denied his

application, but advised that he could reapply when he had secured the requested documentation.

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