Cataldo v. United States Steel Corp.
676 F.3d 542
| 6th Cir. | 2012Background
- Plaintiffs are 225 current/former Lorain, Ohio steel mill employees represented by USW and participant in an ERISA pension plan.
- Plan administration shifted from U.S. Steel to Kobe Pension Fund (1989) and back to Lorain Tubular/U.S. Steel (1999–2001); best-five-years method used with 1999 cutoff.
- Promises in 2003 implied parity with other U.S. Steel employees’ benefits, but the plan was not amended.
- TAP offered early retirement with more favorable pension calculations; some retirees relied on assurances and received reduced benefits.
- Older employees’ benefits still use pre-2000 years; plaintiffs allege ongoing miscalculations and inadequate responses about plan funding.
- Plaintiffs filed suit June 1, 2009 asserting ERISA fiduciary-duty claims, equitable relief, estoppel, failure to furnish plan documents, and common-law claims; district court dismissed all; Sixth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ERISA fiduciary-duty claims time-bar and fraud/concealment exception | Plaintiffs argue six-year period applies due to fraud/concealment. | Defendants contend three-year period applies unless concealment fraud is shown. | Court assumes six-year for fraud/concealment but declines ruling; still finds claims time-barred by pleading failures. |
| Adequacy of pleading fiduciary fraud under Rule 9(b) | Plaintiffs assert fraud via TAP assurances. | Defendants argue no detailed, speaker-specific misrepresentation pleaded. | Pleading fails rule 9(b) specificity; claims dismissed. |
| Whether USW was an ERISA fiduciary | USW allegedly exercised discretionary control and gave plan assurances. | USW not named plan fiduciary; not a de facto fiduciary acting over plan administration. | USW not an ERISA fiduciary; claim properly dismissed. |
| Equitable estoppel viability in pension-plan context | Plaintiffs rely on estoppel due to written representations | Estoppel requires fraud or knowledge with reliance; documents unambiguous; no justifiable reliance. | Equitable estoppel not stated; Bloemker criteria not satisfied. |
| ERISA preemption of state-law claims | Common-law fraud, negligence, etc., relate to plan administration. | ERISA preempts state-law claims that relate to plan administration and require plan analysis. | Common-law claims preempted; affirmed dismissal. |
Key Cases Cited
- Tassinare v. American National Insurance Co., 32 F.3d 220 (6th Cir.1994) (three-year/ six-year considerations for ERISA claims depending on fraud)
- Wright v. Heyne, 349 F.3d 321 (6th Cir.2003) (actual knowledge not knowledge of ERISA violation)
- Brown v. Owens Corning Investment Review Committee, 622 F.3d 564 (6th Cir.2010) (fraud-concealment clause; knowledge timing; alleged concealment after knowledge is insufficient)
- Bartling v. Fruehauf Corp., 29 F.3d 1062 (6th Cir.1994) (actuarial reports must be furnished; residual clause relevance)
- Bloemker v. Laborers' Local 265 Pension Fund, 605 F.3d 436 (6th Cir.2010) (equitable estoppel in pension-plan context requires specific elements)
- Peacock v. Thomas, 516 U.S. 349 (1996) (§1132(a)(3) equitable relief scope)
- Meade v. Pension Appeals & Review Comm., 966 F.2d 190 (6th Cir.1992) (statutory limitations analysis for ERISA actions)
- Kennedy v. Electricians Pension Plan, 954 F.2d 1116 (5th Cir.1992) (limitations and ERISA notice considerations)