Lipshires v. Behan Bros. Inc. Retirement Plan

CourtDistrict Court, D. Rhode Island
DecidedAugust 30, 2021
Docket1:20-cv-00252
StatusUnknown

This text of Lipshires v. Behan Bros. Inc. Retirement Plan (Lipshires v. Behan Bros. Inc. Retirement Plan) is published on Counsel Stack Legal Research, covering District Court, D. Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lipshires v. Behan Bros. Inc. Retirement Plan, (D.R.I. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND ) JEFFREY LIPSHIRES; SARA ) DONNELLY: and ANSELMO TONI ) Plaintiffs, ) ) v. ) ) C.A. No, 20-252-JJM-PAS BEHAN BROS., INC RETIREMENT _ ) PLAN; BEHAN BROS.,, INC.; ) MICHAEL J. BEHAN, JR.; and ) WILLIAM P. BEHAN, ) Defendants. ) ) MEMORANDUM AND ORDER JOHN J. MCCONNELL, JR., United States District Court Chief Judge. Plaintiffs Jeffrey Lipshires, Sara Donnelly, and Anselmo Toni (“Plaintiffs”) filed this suit against Defendants Behan Bros., Inc. Retirement Plan, Behan Bros., Inc., Michael J. Behan, Jr., and William P. Behan (“Defendants”) under the Employee Retirement Income Security Act of 1974, as amended, 29 U.S.C. §§ 1001 e¢ seg. (ERISA), seeking additional retirement benefits representing their respective market losses. Before the Court is Defendants’ Motion for Summary Judgment. ECF No. 16. Because it finds that there are no disputed issues of material fact weighing in favor of Plaintiffs’ claims, the Court GRANTS Defendants’ motion. I, FACTS AND BACKGROUND Jeffrey Lipshires, Sara Donnelly, and Anselmo Toni are retired employees of the Defendant Behan Bros., Inc. and former participants in Defendant Behan Bros., Inc. Retirement Plan (“The Plan”). All three former employees retired in 2018.

The Plan Administrator retained Abacus Benefit Consultants, Inc. (“Abacus”), as a third-party advisor to the Plan. Abacus prepares individual account valuations following the end of each Plan Year. Historically, these valuations have taken between two to eight months to deliver. The Plan requires participants to reach a 1-Year Break in Service, after which the retiree can request a lump sum distribution of their 401k accounts. In this case, Plaintiffs elected not to take their 401k account distributions during 2019, deciding to wait until the year-end December 31, 2019 valuation. Around the same time, the COVID-19 pandemic began to wreak havoc around the world. Not only did millions of people become sick, but it also led to unprecedented volatility in the financial markets, causing a substantial downturn in the stock market. Because the Plan is a 401k profit sharing plan and its assets are held in a pooled investment account, it was negatively affected by the stock market downturn. Before the devastating effects of COVID-19 were truly known, each Plaintiff sought to withdraw their individual balances with a December 31, 2019 valuation date. As the stock market plummeted, they continued to request a December 31, 2019 valuation date but were told that Abacus would prepare those valuations by approximately mid-March within its customary response time. In response to the extreme stock market dips, the Plan Administrator decided to implement a Special Valuation Date (“SVD”) of April 830, 2020, instead of the requested December 31, 2019 date. The Plan Administrator has the sole discretion to declare an SVD in

“extraordinary circumstances” such as where there is “a significant change in economic conditions or Market Value of the Trust Fund.” Plaintiffs lost a combined $55,000 because of the implementation of the April 30, 2020 SVD as opposed to the December 31, 2021 date they sought. Plaintiffs appealed the Plan Administrator’s decision and were denied. In denying the appeal, the Plan Administrator explained that it could not distribute any benefits until Abacus issued its year-end account valuations on March 24, 2020, The Plan Administrator reflected that “[bly March 16, 2020, it was evident that equity markets were down significantly from December 31, 2019, levels. The Dow Jones Industrials had dropped by more than 29%. The Plan’s advisors recommended scheduling a Special Valuation Date in response to recent market volatility. The fiduciary duties of the Plan Administrator (Behan Bros. Inc.) run to the participants and beneficiaries of the Plan as a whole. ERISA, §404, 29 U.S.C. §1104. The Plan Administrator determined that in the interest of Plan participants a Special Valuation Date should be declared in order to recognize recent market changes and treat all Plan participants equitably.” ECF No. 17 { 31. Post appeal, Plaintiffs took their 401k distributions without prejudice or waiver of their rights to seek additional amounts. They filed this suit alleging two claims — one under ERISA, seeking additional retirement benefits from the Plan representing their respective market losses and the second for breach of fiduciary duty. All Defendants moved to dismiss the complaint, which this Court denied. ECF

No. 14. After discovery on Plaintiffs’ claims, all Defendants now ask the Court to dismiss this case on summary judgment. ECF No. 16. II. STANDARD OF REVIEW When ruling on a motion for summary judgment, the court must look to the record and view all the facts and inferences therefrom in the light most favorable to the non-moving party. Continental Cas. Co. v. Canadian Univ. Ins. Co., 924 F.2d 370, 378 (1st Cir. 1991). “Granting summary judgment is appropriate if the moving party ‘shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Ophthalmic Surgeons, Ltd. v. Paychex, Ine., 632 F.3d 31, 35 (st Cir. 2011 (quoting Fed. R. Civ. P. 56(a)). “Once the moving party avers the absence of genuine issues of material fact, the nonmovant must show that a factual dispute does exist, but summary Judgment cannot be defeated by relying on improbable inferences, conclusory allegations, or rank speculation.” Ingram v. Brink’s, Inc., 414 F.3d 222, 228-29 (ist Cir. 2005). “In the summary judgment context, ‘genuine’ has been construed to mean ‘that the evidence about the fact is such that a reasonable jury could resolve the point in favor of the nonmoving party. Similarly, a fact is ‘material’ if it is ‘one that might affect the outcome of the suit under the governing law.” Enica v. Principi, 544 F.3d 328, 336 (1st Cir. 2008) (citations omitted).

II. ANALYSIS

OA ERISA Standard of Review In the confines of the summary judgment standard of review, the Court must apply an ERISA standard of review. Post-argument, it does not appear that the parties disagree on what standard of review this Court should apply to this denial of benefits claim challenged under ERISA § 1182(a)(1)(B). Both agree that an arbitrary and capricious standard is appropriate where “the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan,” Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115 (1989); Leahy v. Raytheon Co., 315 F.3d 11, 15 (1st Cir. 2002). In this case, the Plan gives the Plan Administrator vast discretionary authority. The Plan states that it “has the authority to make factual determinations, to construe and interpret the provisions of the Plan, to correct defects and resolve ambiguities in the Plan and to supply omissions to the Plan. Any construction, interpretation or application of the Plan by the Plan Administrator is final, conclusive and binding.” ECF No. 1-1 at 10. The document also gives the Plan Administrator “sole discretion” to declare an SVD. ECF No. 1-1 at 7.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Lipshires v. Behan Bros. Inc. Retirement Plan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lipshires-v-behan-bros-inc-retirement-plan-rid-2021.