Keister v. American Association of Retired Persons, Inc

CourtDistrict Court, District of Columbia
DecidedDecember 9, 2021
DocketCivil Action No. 2019-2935
StatusPublished

This text of Keister v. American Association of Retired Persons, Inc (Keister v. American Association of Retired Persons, Inc) 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
Keister v. American Association of Retired Persons, Inc, (D.D.C. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

) KIM KEISTER, ) ) Plaintiff, ) ) v. ) Civil Action No. 19-2935 (FYP) ) AMERICAN ASSOCIATION OF ) RETIRED PERSONS, INC., ) ) Defendant. ) )

MEMORANDUM OPINION

Plaintiff Kim Keister was employed by the American Association of Retired Persons, Inc.

(“AARP”) before suffering a stroke that required him to stop working due to lost language and

cognitive skills. Keister was awarded short-term disability payments, but he was denied long-

term disability benefits. When separating from AARP, Keister signed a Severance Agreement

that barred him from pursuing any claim for long-term disability benefits. Keister brings this

lawsuit, arguing that AARP made misrepresentations about the Severance Agreement and

interfered with his right to seek additional disability benefits, in violation of the Employee

Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1001, et seq. See generally ECF No. 1

(Complaint). Before this Court is Defendant’s Motion to Dismiss. See ECF No. 6 (Defendant’s

Motion). 1 AARP argues that Keister’s claims are barred by res judicata because he brought

1 Plaintiff has filed an Opposition, see ECF No. 8, and Defendant filed a Reply, see ECF No. 9. The Court notes that Plaintiff filed his Opposition late. Defendant filed its Motion to Dismiss on November 20, 2019. See Def. Mot. A response to a motion must be filed within 14 days of the date of service. See LCvR 7(b). Plaintiff’s Opposition was thus due on December 4, 2019, but Plaintiff did not file his Opposition until December 5, 2019. See Pl. Opp. Because the Court prefers to decide cases on their merits, the Court accepts the Opposition for filing. The Court also has considered Plaintiff’s and Defendant’s Supplemental Memoranda concerning the appeal of a related case. See ECF No. 11 (Defendant’s Supplemental Memorandum); ECF No. 12 (Plaintiff’s Supplemental Memorandum). claims based on the same facts in a prior lawsuit. For the reasons explained below, the Court

agrees that Keister’s claims are barred by the doctrines of claim preclusion and issue preclusion.

The Court therefore will grant Defendant’s Motion to Dismiss.

BACKGROUND

AARP hired Keister as a news and policy executive editor around April 2004. See

Compl., ¶ 11. Keister was covered by the company’s Long-Term Disability Insurance Plan. Id.,

¶¶ 12–13. On August 19, 2016, Keister suffered a stroke and went on medical leave. Id., ¶¶ 17–

21. The stroke caused Keister to suffer a significant loss of language and cognitive skills. Id., ¶¶

19–21. On January 11, 2017, Keister attempted to return to work, but his cognitive skills had not

yet returned to pre-stroke functionality. Id., ¶ 21. Keister requested medical leave and applied

for short-term disability benefits on February 3, 2017. Id., ¶ 23.

On April 21, 2017, Aetna Life Insurance Co. (“Aetna”) approved Keister for short-term

disability benefits. Id., ¶ 26. The short-term disability benefits ended on August 2, 2017. Id.,

¶ 29. Keister also applied for long-term disability benefits but the claim was denied on July 18,

2017. Id., ¶ 28. Keister appealed the denial of his claim, but Aetna affirmed its decision on June

13, 2018. Id., ¶ 40.

Meanwhile, after Keister’s initial application for long-term disability benefits had been

denied but before he filed his appeal, AARP offered Keister a Severance Agreement. Id., ¶ 35;

see ECF No. 6-2 (Severance Agreement, Ex. A to Def. Mot.). Under the Severance Agreement,

Keister would receive severance pay in exchange for a general release of claims (“Release”).

See Severance Agreement, ¶ 2. The Release provided

In consideration of the promises and benefits contained in this Agreement . . . you hereby fully and forever waive, discharge, and release AARP . . . from any and all claims for damages, personal injuries, discrimination, retaliation, reinstatement, or other relief

2 that you may have . . . based upon your employment, separation, and/or any event or transaction that occurred prior to your signing this Agreement.

Id. The Release specified that it encompassed “any claims of race, sex, age, and other prohibited

discrimination, and any other legal or equitable claim of any kind, whether based upon statute,

contract, tort, common law, ordinance, regulation or public policy . . . .” Id. (emphasis added).

The Release further provided:

It is expressly agreed and understood that this Agreement constitutes a GENERAL RELEASE. You understand that you are releasing claims that you may not know about. This is your knowing and voluntary intent, even though you recognize that someday you might learn that some or all of the facts you currently believe to be true are untrue and even though you might then regret having signed this release. It is further agreed that this consideration shall settle and compromise any claims you have, or may have, whether known or unknown, that existed prior to the date of your signature.

Id. 2 Keister signed the Severance Agreement on September 27, 2017. See id. at 5.

I. Prior Litigation

On October 16, 2018, Keister filed a lawsuit against Aetna and AARP Benefits

Committee (“AARP Benefits”), a wholly owned subsidiary operated by AARP, claiming that

those defendants wrongfully denied his claim for benefits under the Long-Term Disability

Insurance Plan, in contravention of ERISA. See Keister v. AARP Benefits Committee, 410 F.

2 Further, the Severance Agreement provided that, by signing, Keister “acknowledge[d] that the provisions of this Agreement constitute the entire agreement on the matters addressed and that they supersede all prior agreements or understandings with regard to such matters.” Id., ¶ 13. A separate paragraph entitled “Knowing & Voluntary Agreement” states that Keister “affirm[ed]” that he had

not relied upon any representation or statement, written or oral, not set forth in this Agreement; that no other promise or agreement of any kind has been made to or with [Keister] by any person or entity whatsoever to cause [him] to execute this Agreement; . . . and that [he] fully understand[s] the meaning of this Agreement, which is that it constitutes a complete General Release.

Id., ¶ 14.

3 Supp. 3d 244, 248 (D.D.C. 2019) (Keister I). In that case, AARP Benefits filed a motion for

summary judgment on December 10, 2018, arguing that Keister was barred from bringing the

lawsuit because he expressly waived his claim for benefits when he signed the Severance

Agreement. See id. at 249. Aetna filed its own motion for summary judgment on January 23,

2019, making the same argument. See id.

On September 30, 2019, the court in Keister I entered an order granting both Motions for

Summary Judgment. See id. at 261. The court issued a Memorandum Opinion laying out its

reasoning on October 7, 2019. See generally id. The court stated that “by signing the separation

agreement, Keister waived his right to bring [his] claim for long-term disability benefits, which

means that his case cannot proceed as a matter of law.” Id. at 247. The court determined that the

Release in the Severance Agreement was “facially unambiguous with respect to the scope of its

coverage,” id. at 258, and there was “no evidence of fraudulent misrepresentation,” id. at 261.

Keister appealed the decision in Keister I, and the D.C. Circuit affirmed the judgment on

February 23, 2021. See generally Keister v. AARP Benefits Committee, 839 Fed. App’x 559

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