Perry v. International Brotherhood of Teamsters
247 F. Supp. 3d 1
| D.D.C. | 2017Background
- Henry Perry, an African-American who served as an IBT International Trustee (1995–2012), sought lifetime retiree health benefits but was found ineligible because he was a few days short of age 65 and did not have 15 years’ service.
- Perry alleges IBT officials orally promised to “bridge” his service/age so he would qualify; he received written denials in April 2012 and a TBT letter in November 2015 confirming his ineligibility (and stating a one-year limitations period for suit).
- Perry filed an earlier suit (Perry I) against IBT arising from the same facts; the court dismissed that case (order said dismiss without prejudice).
- Perry filed the instant lawsuit (Perry II) against IBT and the Teamsters Benefit Trust (TBT) asserting ERISA §502(a)(1)(B) benefits, ERISA §510 interference/discrimination, §502(a)(3) equitable relief, and a D.C. Wage Act claim.
- Defendants moved to dismiss for res judicata/preclusion, untimeliness, failure to state claims, and improper party; IBT also sought Rule 11 sanctions.
- The court dismissed all claims with prejudice as to both defendants, denied sanctions, and explained reasons: prior dismissal ambiguity, statute of limitations/discovery-rule and equitable tolling analysis, failure to state ERISA §510 and §502 claims, and Wage Act inapplicability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Perry II is precluded by Perry I (res judicata / issue preclusion) | Perry contends prior dismissal left room to refile because order said "without prejudice" | IBT contends Perry I was effectively a 12(b)(6) dismissal on merits and bars relitigation | Court treats Perry I order at face value as without prejudice and declines to apply preclusion |
| Whether Perry's ERISA §510 interference/discrimination claim is timely | Perry argues discovery rule / later TBT letter restarted limitations; seeks equitable tolling for administrative exhaustion | IBT argues claim accrued in 2012 (April 6/11 letters), TBT letter cannot restart time as to IBT, and tolling is not warranted | Court finds claim untimely: discovery rule inapplicable; equitable tolling not justified; complaint untimely |
| Whether Perry stated an ERISA §510 claim (substantive merits) | Perry alleges IBT "discriminated" by failing to bridge him while allegedly doing so for others; contends interference with accrual of benefits | IBT argues §510 protects against interference with benefit rights, not racial discrimination; Perry wasn't discharged and his term simply expired | Court holds ERISA §510 not implicated: allegations fail to plead interference of the sort §510 protects; claim fails under Rule 12(b)(6) |
| Whether Perry stated claims against TBT and under ERISA §502(a)(1)(B) / DC Wage Act | Perry seeks to enforce plan or an exception/reformation based on alleged bridging and Trustees' practices | TBT argues Perry was never eligible under plan terms; equitable reformation not available absent fraud/mistake; DC Wage Act claims fail because Perry is an exempt administrative employee | Court dismisses claims against TBT: no §502(a)(1)(B) entitlement; no allegations warranting equitable reformation against TBT; DC Wage Act claim fails (plausibly exempt and no agreement showing accrued vacation entitlement) |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: complaint must state a plausible claim)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must raise right to relief above speculative level)
- Federated Dep't Stores, Inc. v. Moitie, 452 U.S. 394 (1981) (12(b)(6) dismissal is a judgment on the merits)
- CIGNA Corp. v. Amara, 563 U.S. 421 (2011) (limitations on equitable remedies and role of plan terms; reformation available in limited circumstances)
- Mass. Mut. Life Ins. Co. v. Russell, 473 U.S. 134 (1985) (ERISA protects contractually defined benefits; relief must enforce plan terms)
- Mertens v. Hewitt Assocs., 508 U.S. 248 (1993) (ERISA does not authorize broad equitable relief beyond what statute permits)
- Taylor v. Sturgell, 553 U.S. 880 (2008) (standards for issue preclusion)
- Rafferty v. NYNEX Corp., 60 F.3d 844 (D.C. Cir. 1995) (Rule 11 sanctions required when pleading not well grounded)
- Browning v. Clinton, 292 F.3d 235 (D.C. Cir. 2002) (Rule 12(b)(6) tests legal sufficiency of complaint)