Teamsters Local Union No. 340 v. Eaton

84 F. Supp. 3d 33, 60 Employee Benefits Cas. (BNA) 1133, 2015 U.S. Dist. LEXIS 10778, 2015 WL 413864
CourtDistrict Court, D. Maine
DecidedJanuary 30, 2015
DocketCase No. 2:13-cv-264-JDL
StatusPublished

This text of 84 F. Supp. 3d 33 (Teamsters Local Union No. 340 v. Eaton) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Teamsters Local Union No. 340 v. Eaton, 84 F. Supp. 3d 33, 60 Employee Benefits Cas. (BNA) 1133, 2015 U.S. Dist. LEXIS 10778, 2015 WL 413864 (D. Me. 2015).

Opinion

ORDER ADOPTING THE RECOMMENDED DECISION OF THE MAGISTRATE JUDGE

JON D. LEVY, District Judge.

I. INTRODUCTION AND BACKGROUND

This case is before the court on plaintiff Teamsters Local Union No. 340’s (“Teamsters”) complaint brought under the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.GA. § 1001 et seq. (2013). ECF No. 1. The Teamsters seek a declaratory judgment that they may properly modify the retiree health insurance benefits of certain former employees, including defendants Kenneth L. Eaton (“Eaton”) and Carl Guignard (“Guignard”). Id. After the parties filed cross-motions for judgment on the administrative record, ECF No. 25; ECF No. 26, Magistrate Judge John H. Rich, III issued a Recom[36]*36mended Decision granting the Teamsters’ motion and denying Eaton and Guignard’s motion. ECF No. 29. Eaton and Guig-nard object. ECF No. 32. For the reasons that follow, I adopt the Magistrate Judge’s Recommended Decision.

II. DISCUSSION

Eaton and Guignard object to the Recommended Decision on the ground that the Magistrate Judge “failed to address their detrimental reliance argument])]” ECF No. 32 at 2. In support, they point to an excerpt in their Motion for Judgment on the Administrative Record in which they argue that they “relied on the representations ... regarding their retiree health insurance coverage[.]” Id.; ECF No. 26 at 9. This passage appears in the motion under the heading, “Defendants’ Contractual Right to Receive Health Insurance Coverage Under Local 340’s Retiree Health and Welfare Plan is Vested and not Subject to Reduction or Elimination.” ECF No. 26 at 7. Eaton and Guig-nard’s motion contended that their contractual retirement benefits had vested under ERISA. Id. The motion, along with the other materials before the Magistrate Judge, otherwise made no mention of detrimental reliance or, more generally, the principle of promissory estoppel. See ECF No. 7; ECF No. 16; ECF No. 19; ECF No. 26; ECF No. 28. See also Harvey v. Dow, 2008 ME 192, ¶ 11, 962 A.2d 322 (noting that promissory estoppel claim requires showing a promise, reliance on that promise, and injustice if promise is not enforced).

A party is entitled to de novo review of arguments that were properly raised before the Magistrate Judge. Paterson-Leitch Co., Inc. v. Massachusetts Mun. Wholesale Elec. Co., 840 F.2d 985, 990-91 (1st Cir.1988) (“[A]n unsuccessful party is not entitled as of right to de novo review ... of an argument never seasonably raised before the magistrate.”); see also Vining v. Astrue, 720 F.Supp.2d 126, 128 (D.Me.2010) (“[T]he law is clear in this Circuit that failure to raise an argument before the Magistrate Judge waives it before the District Court.”). To properly raise an argument, a party must do more than “seed[] the record with mysterious references.” Paterson-Leitch, 840 F.2d at 990. Arguments must be spelled out “squarely and distinctly,” and a single sentence reference that fails to cite authority may not suffice. Id.

The passing reference in defendants’ motion to their reliance on representations regarding their benefits, made as part of their argument that they had vested contractual rights, is a far cry from “squarely and distinctly” raising the quasi-contractual theory of detrimental reliance or promissory estoppel as a basis for relief. Because detrimental reliance was not presented to the Magistrate Judge for consideration, Eaton and Guignard have failed to preserve their right to raise the issue as part of my de novo review.

Detrimental reliance being the only issue cited by Eaton and Guignard in their objection to the Recommended Decision, see ECF No. 32, there are no other issues presented for de novo review. See Keating v. Sec’y of Health and Human Servs., 848 F.2d 271, 275 (1st Cir.1988) (“[Ojnly those issues fairly raised by the objections to the magistrate’s report are subject to review in the district court and those not preserved by such objection are precluded on appeal.”).

III. CONCLUSION

It is ORDERED that the Recommended Decision of the Magistrate Judge is hereby ADOPTED. Plaintiffs Motion for Judgment on the Administrative Record is [37]*37GRANTED; defendants’ Motion for Judgment on the Administrative Record is DENIED. Judgment for plaintiff shall issue separately.

SO ORDERED.

RECOMMENDED DECISION ON CROSS-MOTIONS FOR JUDGMENT ON ADMINISTRATIVE RECORD

JOHN H. RICH III, United States Magistrate Judge.

The parties, a union local and two of its former officers and employees, disagree on the terms of a benefit plan in this ERISA action. I recommend that the court grant the plaintiffs motion for judgment on the administrative record and deny that of the defendants.

I. Factual Background

The following facts are taken from the parties’ factual appendices and do not appear to be in dispute.

The plaintiff, Local 340, is a labor organization and an employer of certain employees, including full-time duly elected officers and business agents. Appendix, Plaintiffs Motion for Judgment on the Administrative Record for Judicial Review (“Plaintiffs Motion”) (ECF No. 25), (“PI. App.”), at 11; Appendix, Defendants’ Motion for Judgment .on the Administrative Record for Judicial Review (“Defendants’ Motion”) (ECF No. 26), (“Def. App.”), at [7]. Its executive board is authorized to conduct its affairs under its constitution and by-laws. PI. App. at 11.

Defendant Eaton is a former full-time business agent and recording secretary of Local 340. Def. App. at [7]. Defendant Guignard is a former full-time business agent and secretary-treasurer of Local 340. Id.

Full-time employees of Local 340, including the full-time officers and business agents, have been, at all relevant times, covered by health and welfare plans maintained and administered by Northern New England Benefit Trust (NNEBT)'. PI. App. at 13. The cost of this coverage'is paid out of Local 340’s general treasury, which is funded solely by the dues paid by members. Id.

Local 340’s by-laws authorize the executive board to “from time to time provide the terms and conditions of employment for officers ... including ... health and welfare and retirement benefits” and to “from time to time provide changes therein^]” PI. App. at 11. In 2001, the executive board adopted the retiree health and welfare portion of a proposed “Severance Pay Plan of Teamster Union Local No. 340.” Id.; Retiree Health & Welfare Plan of Teamsters Union Local No. 340 (“the Plan”), Administrative Record at 46-48.

NNEBT also provides a subsidized, pre-Medicare age retiree medical plan for Local 340 members who qualify. PI. App. at 13. Under the plan adopted in 2001, qualified full-time officers and business agents, and their spouses, upon their retirements, could remain covered by the NNEBT plan that covers Local 340’s full-time active employees. Id. The plan included a statement that the benefits provided were “non-forfeitable and non-alienable to the fullest extent permitted by governing law.” Def. App.

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Bluebook (online)
84 F. Supp. 3d 33, 60 Employee Benefits Cas. (BNA) 1133, 2015 U.S. Dist. LEXIS 10778, 2015 WL 413864, Counsel Stack Legal Research, https://law.counselstack.com/opinion/teamsters-local-union-no-340-v-eaton-med-2015.