Sheet Metal Workers' International Ass'n v. Moore

990 F. Supp. 7, 1997 U.S. Dist. LEXIS 21316, 1997 WL 814878
CourtCourt of Appeals for the D.C. Circuit
DecidedNovember 3, 1997
DocketCivil Action No. 95-00646-CKK
StatusPublished
Cited by1 cases

This text of 990 F. Supp. 7 (Sheet Metal Workers' International Ass'n v. Moore) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sheet Metal Workers' International Ass'n v. Moore, 990 F. Supp. 7, 1997 U.S. Dist. LEXIS 21316, 1997 WL 814878 (D.C. Cir. 1997).

Opinion

MEMORANDUM OPINION

KOLLAR-KOTELLY, District Judge.

Plaintiffs, a local sheet-metál workers’ union and several of its members, allege that the trustees of the National Stabilization Agreement of the Sheet Metal Industry Trust Fund breached their fiduciary duty under the Employee Income Retirement Security Act (ERISA), 29 U.S.C. § 1104(a)(1) (1994), by unreasonably invoking the plan’s forfeiture provision to deny them their benefits. Pending before the Court are the parties’ cross-motions for summary judgment and supporting documents. After carefully considering the pleadings and the entire record, the Court determines that there is no genuine dispute as to material facts, see Fed. R. Civ. P. 56(c); Too v.. Freeh, 27 F.3d 635, 638 (D.C.Cir.1994), and grants Defendants’ Motion for Summary Judgment, and denies the Plaintiffs’ motion.

I. BACKGROUND

The National Stabilization Agreement of the Sheet Metal Industry Trust Fund (“SAS-MI”) is an “employee welfare benefit plan” under the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1002(1). Established pursuant to § 302(c)(5) of the Labor Management Rela[9]*9tions Act, 29 U.S.C. § 186(c)(5), see Compl. ¶ 5; Answer ¶ 6, SASMI is operated by a board of trustees whose individual members are “fiduciaries” under ERISA § 3(21)(A), 29 U.S.C. § 1002(21)(A), and are subject to a duty to discharge their obligations for the exclusive purpose of the beneficiaries.1 See Compl. ¶ 7; Answer ¶ 8. The principal benefit of SASMI is the Basic Unemployment and Underemployment Benefit, which provides benefits for eligible members who involuntarily work fewer hours than normal within a predetermined six-month period.2 See Pis.’ Mot. for Summ. J. Ex. 1 (SASMI Summary Plan Description). ' Contributions are determined as a percentage of every dollar paid in wages and fringe benefits to employees and are paid by employers directly to SASMI. See Ferguson Aff. ¶ 5. Applications for benefits are made after the end of a six-month period and payments are contingent on the continued eligibility of the applicant. See Ferguson Aff. ¶ 8.

Plaintiffs were members of Sheet Metal Workers’ International Association, Local Union 19 (“Local 19”), which qualified them as “participants” and “beneficiaries” of SAS-MI under ERISA § 3(7)-(8), 29 U.S.C. § 1002(7)-(8), from 1975 to 1992. See Compl. ¶ 4. In 1984 SASMI promulgated and adopted Article IV, section 2(g) of their Rules and Regulations, which provided that all benefits would be forfeited by members and beneficiaries upon any action by a local union that terminated or in the future would terminate the local union’s participation in SASMI.3 See Defs.’ Mot. for Summ. J. Ex. 5 (Minutes from Trastees’ Meetings June, 1983; November, 1983; and February, 1984). In December 1991, Local 19 voted to withdraw from SASMI effective January 1, 1992. See Compl. ¶ 27; Answer ¶ 18: In 1992 Plaintiffs filed for benefits with SASMI for the second six-month period of 1991. See Kelly First Deel. ¶ 5. SASMI rejected their petitions claiming that, under the forfeiture provisions, all members of Local 19 had forfeited their benefits at the time they voted to withdraw in 1991, accordingly they were not eligible to receive the requested benefits. See Kelly Second Deel. ¶5. Plaintiffs pursued the internal appeals process, and in 1994 their appeals were denied again on the basis that all members of Local 19 had for-féited their benefits eligibility immediately upon voting to withdraw from SASMI in 1991, not upon the effective date of 1992. See id. ¶ 7.

Plaintiffs allege that the SASMI trustees violated their fiduciary duty under ERISA § 404(a)(1), 29 U.S.C. § 1104(a)(1), by unreasonably denying them benefits for a period during which their employer paid the required contributions. They claim that the forfeiture provision is arbitrary and capricious because it does not further a legitimate goal and is instead a punitive, sanction on local unions that withdraw from SASMI. The trustees respond that the forfeiture provision is reasonable in that it furthers the purpose of deterring local unions from entering and leaving SASMI in order to maximize benefits and thus maintains the actuarial and financial stability of the fund. They further allege that the application of the forfeiture provision to the Plaintiffs was reasonable in that the language was clear, their prior practice had been consistent, and Local 19 knew of the forfeiture provision when it voted to withdraw from SASMI.

[10]*10II. DEFENDANTS ARE ENTITLED TO JUDGMENT AS A MATTER OF LAW BECAUSE THE FORFEITURE RULE IS A REASONABLE EXERCISE OF THE TRUSTEES’ DISCRE- ■ TION

This Court’s role is narrowly circumscribed where, as here, an employee-welfare-benefit plan “gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan.” Firestone Tire and Rubber Co. v. Bruch, 489 U.S. 101, 115, 109 S.Ct. 948, 956-57, 103 L.Ed.2d 80 (1989). With language that is virtually unqualified in its breadth, the SASMI Amended and Restated Agreement and Declarations of Trust provides that “[t]he Trustees shall have the sole and absolute discretion to construe the provisions of this Agreement and any construction adopted by the trustees shall be binding upon ... the Locals.” Def.’s Mot. Summ. J., App. I, Ferguson Aff., Ex. 3 (Trust Agreement, art. IV, sec. 2). Moreover, the Rules and Regulations underscore the trustees’ authority by declaring that they “shall also have the sole and absolute discretion to determine ... (3) entitlement to, duration, amount of, or limitations on forfeitability of or loss of benefits eligibility.” See id., App. I, Ferguson Aff., Ex. 2 (Rules and Regulations, art. VIII, see. (b)(3)). Such empowering language “has been comprehended, almost invariably, as conveying ‘discretionary or final .authority’ of the kind that courts check only for reasonableness.” Block v. Pitney Bowes, Inc., 952 F.2d 1450, 1453 (D.C.Cir.1992) (Ginsburg, Ruth Bader, J.) (quoting Firestone, 489 U.S. at 112,109 S.Ct.. at 955) (citation omitted). Indeed, the Fourth Circuit has construed the same SAS-MI provisions as “obviously cloth[ing] the trustees with broad discretion.” Fagan v. Agreement of Sheet Metal Indus. Trust Fund, 60 F.3d 175, 180 (4th Cir.1995). When conducting this review, “courts will substitute their judgment for that of the trustees only if the trustees’ actions are not grounded on any reasonable basis.”

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

Related

Moore v. Blue Cross & Blue Shield of the National Capital Area
70 F. Supp. 2d 9 (District of Columbia, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
990 F. Supp. 7, 1997 U.S. Dist. LEXIS 21316, 1997 WL 814878, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sheet-metal-workers-international-assn-v-moore-cadc-1997.