John Butler v. FCA US, LLC
706 F. App'x 256
| 6th Cir. | 2017Background
- John Butler, a long-time Chrysler employee, was injured in a July 2008 car crash and later filed a claim under Chrysler’s group accident-insurance plan administered by MetLife.
- Butler retired in May 2011 and sought additional benefits (claiming a Total Permanent Disability benefit) six days after retirement; MetLife denied the claim as falling under Traumatic Brain Injury benefits in the July 2008 policy.
- Butler consulted the 2007 Summary Plan Description (SPD), which stated it was the plan document but also said that if it conflicted with the underlying policy, the policy controls.
- The MetLife Certificate (the relevant policy in effect when Butler was injured) did not list a Total Permanent Disability benefit; an earlier policy in effect through Feb 28, 2008 had listed it but the benefit was removed effective March 1, 2008.
- Butler sued under ERISA § 502(a)(1)(B) for benefits and § 1024(b)(4) for failure to provide plan documents; the district court granted summary judgment to Chrysler, and Butler appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Butler is entitled to recover benefits under 29 U.S.C. § 1132(a)(1)(B) | Butler argued the SPD indicated a Total Permanent Disability benefit existed and thus he was entitled to benefits | Chrysler argued the controlling written instrument was the policy (MetLife Certificate) in effect when Butler was injured, which did not include that benefit | Court held Butler cannot recover under § 1132(a)(1)(B) because the operative policy did not include the Total Permanent Disability benefit |
| Whether the SPD was misleading such that equitable relief under 29 U.S.C. § 1132(a)(3) is warranted | Butler argued the SPD’s language (reference to benefits as of 2004 and a taxability note) would mislead an average participant into thinking the benefit remained | Chrysler argued the SPD, read in context, omitted the benefit and explicitly deferred to the policy if conflict existed; omissions and other listed changes showed deliberate amendment | Court held the SPD was not false or misleading in context and did not entitle Butler to relief under § 1132(a)(3) |
| Whether Chrysler violated § 1024(b)(4) by failing to provide the requested plan documents in a timely manner | Butler argued he requested the Group Certificate and Group Policy and that Chrysler’s delay and failure to produce the 2007 policy violated the statute | Chrysler argued Butler’s initial letters were to MetLife/Benefits Express (not the employer), his later emails did not clearly request specific documents, and the requested 2007 policy was not the operative policy and caused no prejudice | Court held Chrysler did not violate § 1024(b)(4) in a prejudicial way and the district court did not abuse its discretion in denying damages |
| Whether district court abused its discretion in denying up to $100/day statutory damages under 29 U.S.C. § 1132(c)(1) | Butler argued delay and nonproduction of the 2007 policy warranted damages | Chrysler argued no clear written request to the employer for that specific document, lack of prejudice, and that the operative policy was provided | Court found no abuse of discretion in denying statutory damages because Butler did not show clear request to employer or prejudice |
Key Cases Cited
- McClain v. Eaton Corp. Disability Plan, 740 F.3d 1059 (6th Cir.) (standard of de novo review for denial of ERISA benefits)
- Bd. of Trs. v. Moore, 800 F.3d 214 (6th Cir.) (when an SPD can be part of the plan’s governing instrument)
- CIGNA Corp. v. Amara, 563 U.S. 421 (U.S.) (equitable relief for misleading SPDs under ERISA § 502(a)(3))
- Kolkowski v. Goodrich Corp., 448 F.3d 843 (6th Cir.) (presumption that participants read SPDs as a whole)
- McCarthy v. Ameritech Publ., Inc., 763 F.3d 469 (6th Cir.) (employer’s disclosure duty under § 1024(b)(4) triggered by a written request to the employer)
- Cultrona v. Nationwide Life Ins. Co., 748 F.3d 698 (6th Cir.) (abuse-of-discretion review and prejudice inquiry for statutory damages under § 1132(c)(1))