Lyday v. Conoco Phillips, 1:08-cv-00144

Lyday seeks ERISA LTD benefits and attendant medical, dental, and life insurance under ConocoPhillips Plan; suit filed as 1:08CV144DN.
Administrative record is partial; plan documents describing eligibility, retirees, decision-makers, and discretion are not in the record, but the parties agree the available record is sufficient for adjudication.
Lyday became disabled at the Woods Cross Refinery; LTD benefits were approved under ConocoPhillips Plan; he later transferred to Holly Corporation in 2003 as part of a sale of the refinery.
Lyday applied for retirement benefits on May 28, 2003 and elected a June 1, 2003 retirement date, including rolling over retirement assets; ConocoPhillips later treated him as retired as of June 1, 2003.
MetLife informed Lyday that his ConocoPhillips LTD benefit would be zero due to offsets for retirement benefits and Social Security; medical insurance was available at retiree rates, not employee rates, after retirement.
Lyday sued in 2008; the district court denied summary judgment for Lyday and dismissed with prejudice, holding Lyday was a ConocoPhillips retiree entitled to retiree rates for medical, dental, and life insurance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lyday retired from ConocoPhillips as of May/June 2003	Lyday did not retire; remained an employee on LTD.	Evidence shows Lyday ended employment as of June 1, 2003 and became a retiree.	Lyday was a retiree; not entitled to employee-rate benefits.
Whether the LTD offset by retirement funds was properly applied	Offset calculation unfair; plan documents control.	Offset is permitted by plan terms; retirement funds reduce LTD.	Abandoned by Lyday; court does not decide.
Whether Lyday is entitled to medical, dental, and life insurance at LTD employee rates vs retiree rates	Lyday should receive active-employee LTD benefits including lower rates for insurance.	As a retiree, Lyday must pay retiree rates for such insurance.	Lyday must pay retiree rates; no entitlement to employee-rate insurance.

Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (Supreme Court 1989) (established arbitrary and capricious review in ERISA benefits denial)
Metropolitan Life Ins. Co. v. Glenn, 554 U.S. 105 (Supreme Court 2008) (conflicts of interest as a factor in review of plan administrator decisions)
Sandoval v. Aetna Life & Cas. Ins. Co., 967 F.2d 377 (10th Cir. 1992) (conflicts of interest weighed as one factor in abuse-of-discretion review)
Foster v. PPG Industries, 693 F.3d 1226 (10th Cir. 2012) (multifactor, sliding-scale approach to arbitrary-and-capricious review with conflicts)
Scruggs v. ExxonMobil Pension Plan, 585 F.3d 1356 (10th Cir. 2009) (application of abuse-of-discretion standard when determining employee vs contractor status)