Frederick Stampone v. Matthew Walker, 17-2660

Background

Plaintiff Frederick Stampone, a member of the United Brotherhood of Carpenters and a Certified Carpenter Steward, sued Pension Defendants (Northeast Carpenters Funds, manager George Laufenberg, NYCDCC Benefits Funds) and Union Defendants (NYC District Council of Carpenters, Matthew Walker).
Two core allegations: (1) Pension Defendants miscalculated his pension benefits and an administrative error initially led to advice he was unvested; (2) Union Defendants suspended his Steward certification for four months without notice or a hearing, costing him job opportunities.
District Court dismissed Stampone’s Third Amended Complaint under Fed. R. Civ. P. 12(b)(6): ERISA claim dismissed for failure to plead exhaustion; LMRA claim dismissed for failure to allege breach of governing documents; LMRDA claim dismissed because Steward suspension was not “discipline” of union membership; other claims (including ADEA reverse-discrimination theory) also dismissed.
On appeal, the Third Circuit vacated and remanded only as to the ERISA pension claim (dismissal as premature because exhaustion was not necessarily pleaded at the complaint stage and evidence submitted below wasn’t fully considered).
The Third Circuit affirmed dismissal of all other claims: LMRA and LMRDA theories lacked plausible pleading or statutory fit; ADEA reverse-discrimination theory fails as a matter of law because ADEA does not prohibit treating older workers more favorably than younger ones.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Stampone’s ERISA benefits claim was properly dismissed for failure to plead exhaustion	Stampone did not need to plead administrative exhaustion in the complaint; exhaustion may be futile and should be resolved later	Pension Defendants argued dismissal was proper because Stampone failed to exhaust administrative remedies	Vacated and remanded as premature; court declined to decide whether pleading exhaustion is required, noted exhaustion is generally an affirmative defense and dismissal at pleading stage was inappropriate here
Whether suspension of Steward certification states an LMRA claim for breach of union governing documents	Suspension violated union rules and deprived Stampone of rights under union bylaws	Union argued no breach of any particular governing provision was pleaded	Affirmed dismissal: complaint failed to allege a plausible LMRA claim or identify a specific breached provision
Whether suspension of Steward certification is actionable discipline under the LMRDA	Stampone treated the suspension as discipline for which LMRDA protections apply	Union argued LMRDA protects discipline of union membership, not Steward certification; no membership suspension alleged	Affirmed dismissal: suspension was not "discipline" of union membership under the LMRDA provision at issue
Whether plaintiff's ADEA theory (including reverse-discrimination of plan favoring >65 over 62–65) is viable	Plan discriminates against 62–65 group by penalizing work in other states while favoring >65 members	Defendants argued ADEA does not forbid favorable treatment of older employees; no plausible personal-discrimination claim alleged	Affirmed dismissal: personal ADEA claim inadequately pleaded; reverse-discrimination theory fails as a matter of law (ADEA permits preferential treatment of older workers)

Key Cases Cited

Harrow v. Prudential Ins. Co. of Am., 279 F.3d 244 (3d Cir.) (discusses ERISA exhaustion at summary judgment stage)
Susinno v. Work Out World Inc., 862 F.3d 346 (3d Cir. 2017) (pleading standard cited)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading-standards framework for plausibility)
Wooddell v. Int’l Bhd. of Elec. Workers, Local 71, 502 U.S. 93 (1991) (LMRA suits for breach of union constitutions/bylaws)
Finnegan v. Leu, 456 U.S. 431 (1982) (scope of LMRDA discipline protections)
Gen. Dynamics Land Sys., Inc. v. Cline, 540 U.S. 581 (2004) (ADEA does not prohibit reverse discrimination)
Jones v. Bock, 549 U.S. 199 (2007) (plaintiffs need not plead facts overcoming affirmative defenses like exhaustion)
Metro. Life Ins. Co. v. Price, 501 F.3d 271 (3d Cir.) (ERISA exhaustion characterized as an affirmative defense)