Farhner v. United Transportation Union Discipline Income Protection Program
645 F.3d 338
| 6th Cir. | 2011Background
- Farhner, a trackman/conductor for KCSR, sought FMLA leave in May 2004 for medical reasons.
- KCSR required specific medical information; Farhner provided a brief doctor’s note, then failed to supply additional requested documentation.
- Farhner was placed on vacation, then instructed to provide detailed medical certification; he did not return to work.
- KCSR issued a Notice of Investigation for insubordination; Farhner was discharged July 30, 2004 for insubordination under CR Rules 1.6 and 1.13.
- Farhner applied for DIPP income-replacement benefits; the Plan excludes insubordination from coverage under section 3.5(b).
- District court granted summary judgment for the Plan; Farhner appealed arguing error in denying benefits and FMLA considerations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether insubordination exclusion governs benefits denial | Farhner argues FMLA protections negate exclusion. | Plan language unambiguously excludes insubordination from coverage. | Plan language unambiguous; denial upheld. |
| Whether Plan Administrator must look beyond plain language to consider FMLA implications | KCSR's FMLA actions could render benefits due despite insubordination. | No duty to look beyond plain terms when unambiguous. | Court may look only to plain terms; no obligation to consider beyond them. |
| Standard of review for ERISA plan denials | Review should be strict given employer involvement in discharge. | Arbitrary and capricious standard with deference to plan language and evidence. | Arbitrary and capricious proper; standard applied and decision affirmed. |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (Supreme Court, 1989) (establishes deferential standard when plan grants discretion)
- Besten v. Delta American Reinsurance Co., 1999 WL 1336061 (6th Cir. 1999) (discusses independent review in insubordination/benefits context)
- Williams v. Int'l Paper Co., 227 F.3d 706 (6th Cir. 2000) (plain-meaning interpretation of ERISA plans)
- Kovach v. Zurich Am. Ins. Co., 587 F.3d 323 (6th Cir. 2009) (plain-meaning and ordinary-language approach to plan terms)
- Wulf v. Quantum Chem. Corp., 26 F.3d 1368 (6th Cir. 1994) (interpretation of ERISA plan language and purpose)
- Callahan v. Rouge Steel Co., 941 F.2d 456 (6th Cir. 1991) (importance of language employees should know in plans)
- Schwalm v. Guardian Life Ins. Co. of Am., 626 F.3d 299 (6th Cir. 2010) (re affirms substantial evidence standard and deference under plan review)