Laurendeau v. Sheet Metal

2006 DNH 132
CourtDistrict Court, D. New Hampshire
DecidedNovember 21, 2006
Docket05CV441-JD
StatusPublished

This text of 2006 DNH 132 (Laurendeau v. Sheet Metal) 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
Laurendeau v. Sheet Metal, 2006 DNH 132 (D.N.H. 2006).

Opinion

Laurendeau v. Sheet Metal 05CV441-JD 11/21/06 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Gerard Laurendeau

v. Civil No. 05-CV-441-JD Opinion No. 2006 DNH 132 Sheet Metal Workers Local 17C-NH Pension Trust

O R D E R

Gerald Laurendeau brought suit under the Employee Retirement

Income Security Act ("ERISA"), challenging the decision of the

Sheet Metal Workers Local 17C-NH Pension Trust ("Pension Trust")

to suspend payment of his pension benefits after he returned to

work. Before the parties filed motions for judgment on the

administrative record, Laurendeau moved to modify the record and

to suspend Local Rule 9.4 to allow additional proceedings in this

case. Both motions were denied. See Order, Oct. 19, 2006 (doc.

no. 23). The court now considers the parties' cross motions for

judgment on the administrative record.

Background

Gerald Laurendeau worked in the sheet metal trade for many

years. He was a participant in the Sheet Metal Workers'

International Local No. 17C-NH Pension Plan, which is

administered by the Pension Trust's Trustees. He took early

retirement in November or December of 2004 and began receiving

pension benefits under the Plan. At a Trustees' meeting on June 8, 2005, one trustee reported

that Laurendeau was working in the trade while receiving pension

benefits. Based on that report, the Trustees decided to suspend

Laurendeau's benefits until he could provide proof that he was

not working in the trade. The Trustees sent Laurendeau a letter

on June 10, 2005, notifying him that his pension benefits would

be suspended on July 1, 2005, based on Section 5.03 of the Plan

and Section 14 of the Summary Plan Description.

Section 5.03(a) of the Plan precludes pension benefits if a

retiree returns to work as "a sheet metal worker or in other

related crafts within the jurisdiction of any local union of the

Sheet Metal Workers' International Association."1 Section 14 of

the Summary Pension Plan provides, in pertinent part:

If you return to employment, other than as a sole proprietor or partner, in the trade, or in other related crafts, within the jurisdiction of any local union of the Sheet Metal Workers' International Association, after you have taken Normal, Early or Deferred Vested Retirement and begun to receive your monthly pension benefit from the Plan, payment of your benefits will be suspended for any calendar month in which you are employed for forty (40) or more Hours of Service.

Section 5.03(b) of the Plan and Section 14 of the Summary Plan

1Section 5.03(a) was amended, effective May 1, 2005, to add a restriction on receiving pension benefits when a retiree resumed work "in any capacity with an employer that is a sheet metal contractor (or is a contractor in other related crafts) that is not a party to, or is otherwise bound by, the Collective Bargaining Agreement with the Union or a collective bargaining agreement with any local union of the Sheet Metal Workers' International Association." Admin. Rec. at 66.

2 Description require a pensioner who returns to work to notify the

Trustees, in writing, of his resumed employment. If a pensioner

returns to work without providing the required notice, the

Trustees may presume that he is engaged in work that disqualifies

him from receiving his pension. A pensioner may rebut the

presumption of disqualifying work by presenting contrary evidence

to the Trustees.

Laurendeau did not file written notice of his resumed

employment. On June 16, 2005, after receiving the letter from

the Trustees, he sent a letter to them denying that he was doing

sheet metal work or any work connected with the trade. He stated

that he was working for B. A. Roy Steel Erectors as a

Miscellaneous Iron and Maintenance Worker. He described his work

at B. A. Roy as follows:

Worked on aluminum & steel truck beds Repair & weld aluminum lower end to boat Weld & repair cast iron parts forcustomers Weld & repair aluminum blocks & trans case for customers Weld & layout structural steel Weld & layout stainless steel railings Weld & repair any shop equipment (forklifts, trucks, etc.) Weld & repair trailers Weld & repair aluminum boats.

J t . St. Mat. Facts 5 16. Laurendeaus letter did not change the

Trustees' decision to suspend his pension benefits.

He appealed that decision in a letter dated August 1, 2005.

In his letter of appeal, Laurendeau again stated that he was

working at B. A. Roy Steel Erectors "as a miscellaneous and

maintenance worker." Ad. Rec. at 146. He also provided a letter

3 from Stanley Ziemba, president of B. A. Roy, which repeated the

list of Laurendeaus work that he had provided previously except

that Ziemba's list omitted "Repair and weld aluminum lower end to

boat." The letter also stated that B. A. Roy did not do HVAC

work. The Trustees denied Laurendeaus appeal because the list

of his work at B. A. Roy included work that the Trustees found

was related to the sheet metal trade based on Article 1, Section

5 of the Sheet Metal Workers International Association

Constitution ("Union Constitution"). That section of the

constitution claims jurisdiction for the Sheet Metal Workers'

Association over certain trades, jobs, and tasks.

The Trust Agreement incorporates the Plan and both give the

Trustees "absolute power and exclusive and complete discretion to

administer the Trust assets in conformity with the Agreement and

Declaration of Trust." The Trustees also have "absolute and

complete power to construe the provisions of [the Trust

Agreement] and the terms used herein, . . . ." The Trustees

have "full authority to determine eligibility requirements for

benefits, in conformance with applicable laws, and to adopt rules

and regulations which shall be binding on the Employees,

Participants and their Beneficiaries." The Plan gives the

Trustees "absolute discretion with respect to the general

administration and interpretation of the Plan . . . ."

Discussion

4 Laurendeau moves to reverse the Trustees' decision to

suspend his benefits or to remand for further proceedings. He

asserts that the ordinary rules of contract interpretation should

apply, that the court should consider evidence outside the

administrative record, and that he is entitled to judgment based

on Cent. Laborers' Pension Fund v. Heinz. 541 U.S. 739 (2004).

The Trust moves for judgment in its favor, contending that the

Trustees' decision is entitled to deferential review, that the

Trustees reasonably found that Laurendeau was working in the

sheet metal trade, and that Heinz does not apply.

To the extent these issues were addressed in the October 19

order those rulings will not be repeated here. Instead, the

court will refer to the prior order unless it is necessary to

provide further explanation.

A. Standard of Review

Where the terms of an ERISA plan give discretion to the plan

administrator to make benefits decisions and to construe the

terms of the plan, "the district court ordinarily should uphold

such determinations by the administrator unless they constitute

an abuse of discretion, or are arbitrary and capricious."

Janeiro v. Urological Surgery Prof.

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2006 DNH 132, Counsel Stack Legal Research, https://law.counselstack.com/opinion/laurendeau-v-sheet-metal-nhd-2006.