Amador v. Boilermaker-Blacksmith National Pension Trust
2:14-cv-02329
D. Kan.Sep 12, 2014Background
- Cases consolidated: Amador and Wilke sue Boilermaker-Blacksmith National Pension Trust (14-2329) and Michael G. Morash (14-2331) seeking benefits and removal of a trustee.
- Actions were originally filed in Wyandotte County, Kansas and removed to federal court under ERISA, 29 U.S.C. § 1001 et seq.
- Plaintiffs allege breach of trust and wrongful denial of benefits, seeking significant monetary damages in 14-2329 and removal of Morash in 14-2331.
- Trust and Morash moved to dismiss for failure to state a claim; plaintiffs moved for summary judgment in both cases.
- Court notes plaintiffs are proceeding pro se, and ultimately grants defendants’ motions to dismiss for failure to state a claim under ERISA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ERISA preemption of state-law claims. | Amador/Wilke contend state-law breach claims survive. | ERISA preempts state-law claims arising from denial of benefits. | Preemption applies; breach claims dismissed. |
| Plaintiffs’ entitlement to benefits under ERISA. | Plaintiffs seek benefits due under the plan. | Benefits claims must be under ERISA and plaintiffs failed to plead abuse of discretion. | No viable ERISA benefits claim stated. |
| Exhaustion of administrative remedies. | Plaintiffs exhausted remedies or were entitled to court relief. | Administrative remedies were not exhausted. | Plaintiffs failed to exhaust administrative remedies. |
| Removal of Morash as trustee under ERISA claims. | Removal of Morash warranted due to fiduciary breaches. | ERISA claims fail; no viable removal basis stated. | No viable claim against Morash; dismissal affirmed. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility standard for complaint sufficiency)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (facial plausibility standard for pleading)
- Ridge at Red Hawk, L.L.C. v. Schneider, 493 F.3d 1174 (10th Cir. 2007) (requirement to plead plausible facts, not mere conclusory statements)
- Dubbs v. Head Start, Inc., 336 F.3d 1194 (10th Cir. 2003) (court assesses facial plausibility on complaint alone)
- Erickson v. Pardus, 551 U.S. 89 (U.S. 2007) (pro se pleadings are liberally construed)
- Hall v. Bellmon, 935 F.2d 1106 (10th Cir. 1991) (liberal construction of pro se pleadings; still must state claim)