Caldwell v. Shaw Industries Group, Inc.
3:13-cv-00391
W.D.N.C.Oct 15, 2013Background
- Caldwell filed an ERISA claim in state court against Shaw, Shaw's Long Term Disability Plan, and Prudential.
- Prudential removed the action to federal court in June 2013.
- Shaw and the Plan moved to dismiss or, alternatively, to strike, arguing lack of control over Prudential’s decisions.
- Plaintiff argued that dismissal was inappropriate and that the case should proceed, possibly with amendments.
- The magistrate judge recommended denying the motion to dismiss without prejudice and ordered Caldwell to file an Amended Complaint by October 28, 2013.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are Shaw and the Plan proper defendants? | Caldwell contends the issue requires fact-specific inquiry and should not be dismissed at this stage. | Shaw and the Plan lack control over Prudential's LTD decisions and thus should be dismissed. | Amended Complaint appropriate; denial of the motion without prejudice. |
| Should the Amended Complaint be allowed to address deficiencies? | Amendment can delete improper sections and clarify claims. | N/A (focus is on whether amendment is appropriate). | Amended Complaint should be allowed; amendment serves efficiency and clarity. |
| Should the motion to strike damages or jury demand be granted? | Jury demand and damages sought are ERISA-appropriate and not improper. | Jury demand and certain damages are improper or vague. | Moot in light of amendment; denial without prejudice. |
Key Cases Cited
- Republican Party of N.C. v. Martin, 980 F.2d 943 (4th Cir. 1992) (standard for Rule 12(b)(6) sufficiency)
- Eastern Shore Markets, Inc. v. J.D. Assoc. Ltd. Partnership, 213 F.3d 175 (4th Cir. 2000) (factual sufficiency standard and pleading requirements)
- Ashcroft v. Iqbal, 129 S. Ct. 1937 (U.S. 2009) (pleading standard: plausibility required)
- Twombly, 550 U.S. 544 (U.S. 2007) (plausibility standard for pleading)
- Erickson v. Pardus, 551 U.S. 89 (U.S. 2007) (notice pleading; liberal construction of complaints)
- Papasan v. Allain, 478 U.S. 265 (U.S. 1986) (context of accepting factual allegations as true)
- Young v. City of Mount Ranier, 238 F.3d 567 (4th Cir. 2001) (amended pleadings supersede prior complaints)
- Colin v. Marconi Commerce Systems Employees' Retirement Plan, 335 F. Supp. 2d 590 (M.D.N.C. 2004) (amended pleadings and mootness of prior motions)
- Turner v. Kight, 192 F. Supp. 2d 391 (D. Md. 2002) (pleadings and amendment principles)