Henderson v. UPMC
640 F.3d 524
| 3rd Cir. | 2011Background
- Henderson, a registered nurse for UPMC, sues for ERISA and wage-law claims claiming unpaid hours during meal breaks and pre-shift prep time.
- ERISA plans at issue include two defined-contribution Savings Plans and a Cash Balance Basic Retirement Plan; compensation is defined as Box 1 W-2 pay.
- Alleged duty: UPMC as employer must maintain records to determine benefits due and to ensure proper contributions as a fiduciary.
- District Court granted dismissal, holding plan language tied benefits to paid wages; hours worked were not required by the plans.
- This appeal addresses whether ERISA §209(a)(1) requires record-keeping of unpaid hours and whether fiduciary duties extend to monitoring contributions.
- Court reviews de novo a district court’s Rule 12(b)(6) dismissal for failure to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of §209 record-keeping duty | Henderson argues records must cover uncompensated hours to determine benefits. | UPMC contends plan definitions tie contributions to paid compensation, not hours worked. | §209 duty governed by plan language; only paid compensation records required. |
| Plan language governing compensation | Compensation should include hours worked for benefit calculations. | Compensation is defined as Box 1 W-2 pay, not hours worked. | Contributions linked to paid compensation; hours worked are not required. |
| Fiduciary duties under §404(a) after §209 ruling | UPMC as fiduciary must ensure hours worked are credited toward contributions. | No §209 claim, so fiduciary duty to monitor contributions fails. | No viable §404 fiduciary claim given §209 dismissal; proceeds barred. |
| Remedies under ERISA after state wage action | Seeking benefits and equitable relief under ERISA if hours were due. | Plan-based calculation based on paid compensation; relief inappropriate here. | Dismissal affirmed for §209 and related fiduciary claims; possibility of future §502(a)(1)(B) claim if state wage case succeeds remains. |
Key Cases Cited
- Trs. of the Chi. Painters & Decorators Pension Fund v. Royal Int'l Drywall & Decorating, Inc., 493 F.3d 782 (7th Cir. 2007) (analyzes §209 duty by plan language and contributions basis)
- Mich. Laborers' Health Care Fund v. Grimaldi Concrete, Inc., 30 F.3d 692 (6th Cir. 1994) (record-keeping scope guided by plan terms)
- Combs v. King, 764 F.2d 818 (11th Cir. 1985) (plan-based interpretation of compensation for contributions)