Dakota, Minnesota & Eastern Railroad v. Schieffer
711 F.3d 878
8th Cir.2013Background
- DM & E and Kevin Schieffer executed an Employment Agreement in 2004 to retain him after a contemplated control change.
- In October 2008, with a merger looming, DM & E terminated Schieffer without cause, triggering severance provisions.
- Schieffer demanded arbitration; DM & E sought federal court injunction of arbitration, asserting ERISA-based federal question jurisdiction.
- On appeal, we held the Employment Agreement is not an ERISA plan but remanded to consider whether some demands are governed by ERISA.
- On remand, the district court dismissed for lack of jurisdiction, finding Schieffer’s demands were under a freestanding single-employee contract linked to ERISA plans but not arising from ERISA plans themselves.
- DM & E appeals, and the circuit affirms the dismissal, ruling there is no federal jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal question jurisdiction exists if ERISA governs some claims | Schieffer argues some demands fall under ERISA as benefits under plans. | DM & E contends the demands are under a freestanding contract, not ERISA benefits. | No ERISA jurisdiction; demands not benefits under ERISA plans. |
| Declaratory Judgment Act jurisdiction independent of FAA | Schieffer can seek relief that could be coercively brought in federal court. | Declaratory judgment does not create jurisdiction; FAA would also not confer jurisdiction. | No independent jurisdiction; DJA does not expand jurisdiction here. |
| Whether Employment Agreement amendments or promises create ERISA plan benefits | Employment Agreement could amend or promise Plan benefits. | Agreement is a complete freestanding contract; it does not amend or fund ERISA plans. | Not ERISA-plan benefits; no jurisdiction over arbitrability under ERISA. |
Key Cases Cited
- Stearns v. NCR Corp., 297 F.3d 706 (8th Cir. 2002) (facets of a multi-faceted contract may fall under ERISA or state law)
- Crews v. Gen. Am. Life Ins. Co., 274 F.3d 502 (8th Cir. 2001) (ERISA plan amendments and scope considerations)
- Johnson v. U.S. Bancorp, 387 F.3d 939 (8th Cir. 2004) (promises of plan benefits not necessarily ERISA plans)
- Eide v. Grey Fox Tech. Servs. Corp., 329 F.3d 600 (8th Cir. 2003) (colorable ERISA-benefits claim requires foundation in ERISA plans)
- Antolik v. Saks, Inc., 463 F.3d 796 (8th Cir. 2006) (interpretations of ERISA-plan-benefits vs. post-termination promises)
- Stevenson v. Bank of N.Y. Co., 609 F.3d 56 (2d Cir. 2010) (funding and administration considerations in ERISA context)
- Gresham v. Lumbermen’s Mut. Cas. Co., 404 F.3d 253 (4th Cir. 2005) (ERISA benefits context and non-ERISA contract boundaries)