Oakman v. International United Automobile Aerospace and Agricultural Workers

CourtDistrict Court, W.D. Kentucky
DecidedAugust 6, 2025
Docket1:23-cv-00026
StatusUnknown

This text of Oakman v. International United Automobile Aerospace and Agricultural Workers (Oakman v. International United Automobile Aerospace and Agricultural Workers) is published on Counsel Stack Legal Research, covering District Court, W.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oakman v. International United Automobile Aerospace and Agricultural Workers, (W.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY BOWLING GREEN DIVISION CIVIL ACTION NO. 1:23-CV-00026-GNS-HBB

GARY OAKMAN PLAINTIFF

v.

GENERAL MOTORS HOURLY RATE EMPLOYEES PENSION PLAN et al. DEFENDANTS

MEMORANDUM OPINION AND ORDER This matter is before the Court on Defendant’s Motion for Judgment on the Administrative Record (DN 58) and Plaintiff’s Cross-Motion for Judgment on the Administrative Record (DN 63). The motions are ripe for adjudication. I. BACKGROUND Plaintiff Gary Oakman (“Oakman”) brought this suit against the General Motors Hourly Rate Employees Pension Plan (“The Plan”) and Fidelity Investments (“Fidelity”), as The Plan’s administrator1, to recover benefits pursuant to the Employee Retirement Income Security Act (“ERISA”). (Am. Compl. ¶ 1, DN 34).2 Oakman was an employee of General Motors (“GM”) from April 17, 1995, to October 31, 2022. (Notice Filing Attach. 1, at 1-3, DN 57-1 [hereinafter Admin. R.]). Prior to working for GM, Oakman was employed by American Sunroof Corporation (“ASC”) on September 27, 1989. (Am. Compl. ¶ 12; Admin. R. 6). Oakman became a GM

1 Fidelity Investments was served on March 6, 2023 (DN 7) and again on April 26, 2023 (DN 21). This party has not filed an answer or a motion. 2 Oakman initially named two additional Defendants in his Amended Complaint: (1) International United Automobile Aerospace and Agricultural Workers Local Union 1714 of Lordstown, OH, and (2) International United Automobile Aerospace and Agricultural Workers Local Union 1618 of Detroit, Michigan. (Am. Compl. ¶ 1). By agreed order, these parties were dismissed. (Agreed Order, DN 45). employee as part of a joint venture between GM and ASC, in which certain ASC employees could join GM to work at the Lansing Craft Center, incentivized by the ability for each transfer employee to retain her/his seniority status from ASC. (Admin. R. 9). The crux of this dispute concerns whether Oakman’s credited years of service in determining his pension benefits under The Plan should include the time he worked for ASC. (See

Am. Compl. ¶¶ 12-24). While employed by ASC, Oakman was not covered under The Plan, as he was not yet a GM employee. (Admin. R. 6). Oakman’s membership in The Plan began on his first date of employment with GM. (Admin. R. 6). Oakman contends that part of the joint venture between GM and ASC provided that ASC employees would be credited by The Plan for the time they were employed by ASC. (Am. Compl. ¶ 15). The GM Benefits & Services Center (“GM Benefits”) has stated that “[t]here was no agreement for [The Plan] to assume responsibility for any credited service earned while an employee of ASC.” (Admin. R. 6). The terms of the joint venture stated: ASC employees . . . will receive, as their Plant Seniority date, 1-7-85, or their ASC hire date, whichever is later. They will receive a [GM] seniority date equal to their ASC hire date. The [GM] seniority date will be utilized as the date established for each employee for vacation pay allowance and paid absence allowance credit . . . .

(Admin. R. 12). At the time he joined GM in 1995, Oakman believed that this utilized “seniority date” would also include his credited years of service to ASC and be included in his pension calculation under The Plan. (Pl.’s Resp. Def.’s Mot. J. Admin. R. & Br. Supp. Pl.’s Mot. J. Admin. R. 3, DN 63-1 [hereinafter Pl.’s Resp. Def.’s Mot. J. Admin. R.]3 (“At the time, the employees did

3 Oakman’s response to The Plan’s motion for judgment on the administrative record and his own memorandum in support of a cross-motion for judgment on the administrative record are contained in one document (DN 63-1). For the sake of clarity, this document will be referred to as Plaintiff’s Response to Defendant’s Motion for Judgment on the Administrative Record. not know or understand that there was such a distinction between credited service and seniority . . . .”)). In 2007, Oakman inquired into his credited service time under The Plan, and a GM Benefits audit, dated June 26, 2008, indicated that Oakman’s credited service was changed from 13.8 years to 19.1 years (i.e., taking into consideration his ASC service time). (Admin. R. 34-35). This

change was apparently due to an erroneous application of a 2007 provision to Oakman’s credited service. (See Admin. R. 35, 306). In November 2017, Oakman’s records still indicated that his time at ASC was included in his credited service under The Plan. (Notice Filing Attach. 2, at 307, DN 57-2 [hereinafter Oakman Docs.]). In 2019, GM Benefits undertook an internal review of the joint venture between GM and ASC. (Admin. R. 305-06). As a result of the review, GM Benefits clarified that Oakman “is not eligible for additional service for the 2007 provision . . . . The 2007 Provision is for filling in for layoff periods not covered by bank[,] not periods not employed by GM[.]” (Admin. R. 306). Thus, in March 2019, an additional audit changed his credited service from 29.5 years back to 24.2 years (i.e., beginning with his start date at GM and not including his

time with ASC). (Admin. R. 306). The review concluded that the joint venture employees should receive seniority dates based upon their start date with ASC, but that they did not “start ‘earning’ GM credited service until they were actually hired by GM . . . .” (Admin. R. 305). Oakman was made aware of this change to his credited service and its reasoning on March 7, 2019. (Admin. R. 37, 309-26). In October 2020, GM and the union responsible for organizing the joint venture discussed the fact that many of the former-ASC employees were confused by the distinction between a seniority date and date of credited service. (Oakman Docs. 306-08). During this communication, GM acknowledged that Oakman initially “did receive credit service for the ASC time[,] but that was taken back.” (Oakman Docs. 315). Oakman retired from GM on October 31, 2022, and a GM audit totaled 28 years of credited service in calculating his retirement benefits. (Admin. R. 1-4). GM Benefits relayed the results of this audit to Oakman on November 17, 2022. (Admin. R. 5). Oakman then initiated an appeal to recover the ASC time that was retracted from his credited service, but his appeal was denied by The Plan’s Pension Committee. (Admin. R. 6-7). Oakman

based his appeal on both the alleged promise that his credited service would include his time at ASC as well as a provision in The Plan’s terms which appeared to bolster this belief. (Admin. R. 6; Oakman Docs. 60-61). The Pension Committee explained that the terms of the GM-ASC joint venture included that the transfer employees would keep their seniority dates “for vacation pay allowance and paid absence allowance[,]” but that there was no agreement for The Plan to assume any credited service for the employees’ pension calculation based upon their time working for ASC. (Admin. R. 6). In the current case, Oakman seeks review of the Pension Committee’s decision to deny him his additional benefits. The Amended Complaint states one cause of action: recovery of denied benefits under 29 U.S.C. § 1132(1)(B) [hereinafter ERISA § 502(a)(1)(B)]. (Am. Compl. ¶ 27).4

The Plan has moved for judgment on the administrative record. (Def.’s Mot. J. Admin. R., DN 58). Oakman has responded and filed a cross-motion for judgment on the administrative record. (Pl.’s Cross-Mot. J. Admin. R., DN 63).

4 Elsewhere in the Amended Complaint, Oakman states that he “also has standing to bring this action pursuant to 29 U.S.C. § 1132(a)(3)(A) & (B) [hereinafter ERISA § 502(a)(3)(A), (B)] . . .

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Oakman v. International United Automobile Aerospace and Agricultural Workers, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oakman-v-international-united-automobile-aerospace-and-agricultural-kywd-2025.