United States First Circuit

In this Employment Retirement Income Security Act (ERISA) case, defendant-employer undertook a final calculation of plaintiff's pension which yielded monthly payments substantially lower than earlier estimates had suggested. Plaintiff thereafter claims seeking the higher amount under ERISA section 502(a)(1), 29 U.S.C. section 1132(a)(1), a theory of estoppel, and Puerto Rico contract law. Dismissal of plaintiff's ERISA and contract claims is affirmed, where: 1) plaintiff could not be awarded relief under the terms of defendant's retirement plan and ERISA preempted the commonwealth law claims; and 2) estoppel could not apply given that the terms of the benefits plan were unambiguous.

Appellate Information

• Decided 12/18/2014
• Published 12/18/2014

Judges

• Lipez

Court

• United States First Circuit

Counsel