United States Sixth Circuit

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Price v. Bd. of Trustees of the Indiana Laborer's Pension Fund, 09-3897

In plaintiff's suit against his pension plan challenging the denial of his benefits and claiming that the plan amendment to limit the payment of occupational disability benefits to a period of two years violated ERISA because his occupational disability benefits had vested as a matter of law, district court's grant of plaintiff's motion for summary judgment is vacated and remanded where: 1) this case is properly understood under a different framework that does not include either Yard-Man or Sprague, as case law has not addressed whether the Yard-Man inference can be appropriately applied outside the context of retiree health benefits and the benefits at issue in Sprague were specifically characterized as unilaterally offered benefits and not bargained-for benefits as present in this case; and 2) the district court did not review the Board's determination under the arbitrary and capricious standard, as if the plan gives the Board discretion to interpret its terms, the essence of this case turns on the reasonableness of the Board's decision.

Appellate Information

  • Argued 08/06/2010
  • Decided 01/12/2011
  • Published 01/12/2011

Judges

Court

  • United States Sixth Circuit

Counsel

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