738 F.3d 282
D.C. Cir.2013Background
- Ian Phillip James appeals a denial of benefits by the International Painters and Allied Trades Industry Pension Plan; the key factual dispute is whether James accrued enough credit under the Local 963 Plan, merged into the International Plan, for 1959–1962; contemporaneous records for that period are sparse; the International Plan denied most benefits citing insufficient accrued credit; James sued in district court arguing de novo review due to claimed irregularities; the district court applied abuse-of-discretion review and denied relief; on appeal the issue is whether procedural irregularities warrant de novo review, and the court affirms deferential review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review given irregularities | James urges de novo review due to record irregularities | Int’l Plan argues deferential review remains appropriate | Deferential review applies; no ERISA irregularity warranting de novo |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989) (establishes deferential review when discretion is granted)
- Conkright v. Frommert, 559 U.S. 506 (2010) (rejects one-strike approach to ERISA review)
- Atkins v. Bert Bell/Pete Rozelle NFL Player Ret. Plan, 694 F.3d 557 (5th Cir. 2012) (circuit approach to procedural irregularities varies by court)
- Trs. of Electricians’ Salary Deferral Plan v. Wright, 688 F.3d 922 (8th Cir. 2012) (addresses procedural irregularities and standard of review)
- Anderson v. Suburban Teamsters of N. Ill. Pension Fund Bd. of Trs., 588 F.3d 641 (9th Cir. 2009) (procedural irregularities and review standard)
- LaAsmar v. Phelps Dodge Corp., 605 F.3d 789 (10th Cir. 2010) (limits impact of irregularities on standard of review)