TAYLOR v. SHEET METAL WORKERS' NATIONAL PENSION FUND

CourtDistrict Court, D. New Jersey
DecidedJanuary 3, 2025
Docket1:24-cv-04321
StatusUnknown

This text of TAYLOR v. SHEET METAL WORKERS' NATIONAL PENSION FUND (TAYLOR v. SHEET METAL WORKERS' NATIONAL PENSION FUND) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
TAYLOR v. SHEET METAL WORKERS' NATIONAL PENSION FUND, (D.N.J. 2025).

Opinion

[ECF No. 33]

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY CAMDEN VICINAGE

STULTZ G. TAYLOR,

Plaintiff, Civil No. 24-4321 (CPO/EAP) v.

SHEET METAL WORKERS’ NATIONAL PENSION FUND, et al.,

Defendants.

MEMORANDUM ORDER

This matter having been opened to the Court on Plaintiff Stultz G. Taylor’s Motion for Reconsideration, ECF No. 33 (“Pl.’s Mot.”), of the Court’s October 11, 2024 Memorandum Opinion and Order, ECF Nos. 29, 30; and Defendants Sheet Metal Workers’ National Pension Fund and the Board of Trustees of the Sheet Metal Workers’ National Pension Fund, as Administrator of the Pension Plan of the Sheet Metal Workers’ National Pension Fund (collectively, “Defendants”) having opposed the Motion, ECF No. 38 (“Defs.’ Opp’n”); and the Court having considered the parties’ submissions; and the Court deciding this matter without oral argument pursuant to Federal Rule of Civil Procedure 78(b) and Local Civil Rule 78.1; and for the following reasons; and for good cause shown: Relevant Background 1. The facts in the Complaint were set forth in detail in the Court’s October 11, 2024 Opinion. Taylor v. Sheet Metal Workers’ Nat’l Pension Fund, No. 24-4321, 2024 WL 4471683 (D.N.J. Oct 11, 2024). For purposes of judicial efficiency, the Court incorporates by reference the recitation of facts therein. Id. at *1-3. 2. Generally, the Complaint alleges that Plaintiff, a former union sheet metal worker and member of the Fund, sought to receive an early retirement pension but was denied. Plaintiff challenges the propriety of Defendants’ decision. See ECF No. 1 (Compl.) ¶¶ 11-71. 3. On March 28, 2024, Plaintiff filed a Complaint in this Court setting forth the following causes of action: (1) failure to provide benefits pursuant to Employee Retirement Income Security Act, 29 U.S.C. § 1001, et seq. (“ERISA”), ECF No. 23 (Count I), ¶¶ 73-78; (2) breach of fiduciary duty (Count II), id. ¶¶ 79-93; (3) estoppel (Count III), id. ¶¶ 94-108; and

(4) failure to provide a full and fair review (Count IV), id. ¶¶ 109-117. 4. On June 17, 2024, the Court held an initial scheduling conference, at which time the parties raised a dispute about the propriety of discovery outside of the administrative record. See ECF No. 20. The Court ordered the parties to provide briefing on the issue. See id. ¶ 2. Following review of that briefing, the Court denied Plaintiff’s request for additional discovery outside of the administrative record. Taylor v. Sheet Metal Workers’ Nat’l Pension Fund, No. 24-4321, 2024 WL 4471683 (D.N.J. Oct. 11, 2024). 5. On October 24, 2024, Plaintiff filed the current Motion for Reconsideration of that Order. See ECF No. 33. Defendant has opposed the Motion. See ECF No. 38. Standard of Review

6. “[R]econsideration is an extraordinary remedy, that is granted ‘very sparingly.’” Brackett v. Ashcroft, No. 03-3988, 2003 WL 22303078, at *2 (D.N.J. Oct. 7, 2003) (quoting Interfaith Cmty. Org. v. Honeywell Int'l Inc., 215 F. Supp. 2d. 482, 507 (D.N.J. 2002)); see also Langan Eng’g & Env’t Servs., Inc. v. Greenwich Ins. Co., No. 07-2983, 2008 WL 4330048, at *1 (D.N.J. Sept. 17, 2008) (explaining that a motion for reconsideration under Local Civil Rule 7.1(i) is “‘an extremely limited procedural vehicle,’ and requests pursuant to th[is] rule[ ] are to be granted ‘sparingly’” (quotation omitted)). To prevail on a motion for reconsideration, the moving party must show at least one of the following grounds: “(1) an intervening change in the controlling law; (2) the availability of new evidence that was not available when the court [made its initial decision]; or (3) the need to correct a clear error of law or fact or to prevent manifest injustice.” Max’s Seafood Café ex rel. Lou-Ann, Inc. v. Quinteros, 176 F.3d 669, 677 (3d Cir. 1999). 7. A motion for reconsideration “may not be used to relitigate old matters, nor to raise arguments or present evidence that could have been raised prior to the entry of judgment.”

P. Schoenfeld Asset Mgmt., LLC v. Cendant Corp., 161 F. Supp. 2d 349, 352 (D.N.J. 2001) (citation omitted). Instead, reconsideration is only proper when “‘dispositive factual matters or controlling decisions of law’ were presented to the court but were overlooked.” Buffa v. N.J. State Dep’t of the Judiciary, 56 F. App’x 571, 575 (3d Cir. 2003) (quoting Resorts Int’l v. Greate Bay Hotel & Casino, 830 F. Supp. 826, 831 (D.N.J. 1992)). Discussion 8. Plaintiff does not challenge the legal propriety of the Court’s ruling on his Count I claim of denial of ERISA benefits under § 502(a)(1), thus conceding that discovery beyond the administrative record is not proper as to that claim. See generally Pl.’s Mot. at 3-5. Instead, Plaintiff alleges that the Court made two errors of law in denying his request for discovery

outside the administrative record. First, he asserts that the Court improperly construed his allegations in Counts II to IV of the Complaint as state law claims that were likely preempted by ERISA. Plaintiff contends that these Counts were actually claims under ERISA § 502(a)(2) for breach of fiduciary duty and § 502(a)(3) for equitable relief, to which the abuse of discretion standard does not apply and for which he is entitled to discovery. See Pl.’s Mot. at 3-11. 9. Second, Plaintiff argues that the Administrative Record is incomplete, and discovery should be allowed to confirm what documents, if any, were provided to and considered by the Appeals Committee. See Pl.’s Mot. at 11-12. 10. The Court considers each argument individually. A. Whether the Court Erred in Finding Counts II to IV Were Likely Preempted 11. Plaintiff’s first argument is that the Court mischaracterized Counts II through IV of his Complaint as state law claims likely preempted by ERISA. See Pl.’s Mot. 3-11. He asserts

that these Counts are, in fact, ERISA claims brought pursuant to §§ 502(a)(2) and 502(a)(3). Pl.’s Mot. at 4-5. Plaintiff avers that such claims are not subject to the more deferential abuse of discretion standard based solely on the administrative record, but rather, they may be the subject of additional discovery. Id. at 6-11. In light of these alleged errors of law, Plaintiff claims that reconsideration is proper. Id. 12. Plaintiff’s arguments fail on one basic proposition: Counts II, III, and IV do not plead claims pursuant to ERISA §§ 502(a)(2) and 502(a)(3). 13. With respect to Count II of the Complaint, Plaintiff labels his cause of action as “Breach of Fiduciary Duty.” Although he cursorily references ERISA, he does not specifically cite to ERISA § 502(a)(2) when he sets forth the following allegations:

80. The Board of Trustees and Jane Does, 1-10, are fiduciaries under the Fund pursuant to ERISA.

81. As fiduciaries of the Fund, these defendants are required to discharge their duties to the Fund in accordance with ERISA and the documents and instruments governing the Fund.

82. As fiduciaries of the Fund, each of these defendants is required to strictly comply with ERISA and the documents and instruments governing the Fund.

83. As fiduciaries of the Fund, each of these defendants was responsible for carrying out their duties for the exclusive purpose of providing benefits to participants and beneficiaries. 84. As fiduciaries of the Fund, each of these defendants was required to discharge its duties in a manner of a prudent person with the care, skill, prudence, and diligence of a person acting in a like capacity and familiar with such matters.

85. Mr.

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