Deppenbrook ex rel. RTI Beaver Falls Employees v. Pension Benefit Guaranty Corp.
414 U.S. App. D.C. 212
| D.C. Cir. | 2015Background
- PBGC terminated RTI employees' pension plans after RTI's bankruptcy filing; plan termination date disputed between PBGC and RTI/participants; shutdown benefits tied to termination date and a break in continuous service; WARN Act notice addressed but not treated as a plan‑level waiting period; ERISA distinguishes defined benefit vs. defined contribution and PBGC insures nonforfeitable benefits only as of termination date; Deppenbrook sought review of PBGC benefit determinations in district court after PBGC Appeals Board denial; district court granted summary judgment for PBGC; on appeal, court applies Chevron/Skidmore framework to interpret ERISA and PBGC regulations; court ultimately affirms the district court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Shutdown benefits vesting timing | Deppenbrook. terminated before June 14, 2002 | PBGC proper termination date June 14, 2002 | Shutdown benefits vest after plan termination date; May 1 WARN not a waiting period; no vesting |
| Insurance of individual accounts | ERISA §1321(c)(1) requires insuring the individual account | ERISA §1321(b)(1) excludes individual accounts from PBGC insurance | PBGC properly refused to insure the individual account portion |
| Unlawful amendment to plan | PBGC amended plan to require distribution of individual account | ERISA gives PBGC broad authority to amend under subchapter; 1054 not applicable to PBGC | District court correct; PBGC amendment not barred by §1054; affirmed |
Key Cases Cited
- PBGC v. Fed. Labor Relations Auth., 967 F.2d 658 (D.C.Cir.1992) (PBGC administrative framework and termination authority)
- RTI, 386 F.3d 659 (6th Cir.2004) (plan termination date disputes; shutdown benefits at issue)
- Hughes Aircraft Co. v. Jacobson, 525 U.S. 432 (Supreme Court 1999) (defined benefit vs. defined contribution; plan guarantees)
- LTV Corp., 496 U.S. 633 (Supreme Court 1990) (ERISA insurance limits; nonforfeitable benefits at termination)
- Nachman Corp. v. PBGC, 446 U.S. 359 (Supreme Court 1980) (nonforfeitable/vested concepts in termination context)
- Connolly v. PBGC, 475 U.S. 211 (Supreme Court 1986) (distinguishing insured vs. noninsured benefits under ERISA)