Richard P. Sullivan v. Coventry Municipal Employees' Retirement Plan
203 A.3d 483
R.I.2019Background
- Sullivan served in various part-time town roles from 1986–2008 and sought pension benefits under successive Coventry municipal plans (1977, 1997 restatement, 2008 restatement).
- After an administrative delay, Sullivan sued in Superior Court (breach of contract, specific performance, and declaratory relief) challenging denial or non-response to his pension claim.
- Superior Court initially denied defendants’ dismissal motion, remanded for an administrative hearing, and later the plan administrator unanimously denied benefits following a hearing.
- Superior Court later dismissed Sullivan’s complaint for lack of subject-matter jurisdiction (holding certiorari to the Supreme Court was the proper vehicle for review of quasi-judicial town-council actions) and alternatively granted summary judgment for defendants under an arbitrary-and-capricious review.
- The Supreme Court reinstated Sullivan’s certiorari petition, reviewed the plan administrator’s decision under the arbitrary-and-capricious standard (the plan vested discretion in the administrator), and affirmed the denial of pension benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Superior Court had subject-matter jurisdiction to review the town council/plan administrator’s denial of pension benefits | Sullivan: Superior Court has jurisdiction under general equity powers and statutes (§§ cited) to hear breach of contract and declaratory-judgment claims | Defendants: Plan administrator acted quasi-judicially; review lies by certiorari to the Supreme Court, not Superior Court | Held: Superior Court lacked jurisdiction; appeal of quasi-judicial town-council action must proceed by certiorari to this Court |
| Proper standard to review plan-administrator decision | Sullivan: Superior Court should review de novo or judge’s review; administrator’s decision was unsupported, biased, and incorrect | Defendants: Plan vests discretionary authority; arbitrary-and-capricious standard applies; administrator’s decision was supported | Held: Plan grants discretion; arbitrary-and-capricious standard applies |
| Whether plan administrator acted arbitrarily or capriciously in denying benefits | Sullivan: Decision lacked substantial evidence, ignored consultant opinion, misapplied ambiguous term “administrative employee,” and showed bias | Defendants: Decision was rational, considered testimony and records, and reasonably construed plan context/history | Held: Decision was rational, supported by testimony and records, not arbitrary or capricious; denial affirmed |
| Whether Corrente or statutory provisions change the proper forum | Sullivan: Corrente and statutes confer Superior Court jurisdiction | Defendants: Corrente is distinguishable; statutes cited do not apply here | Held: Corrente is distinguishable (it involved newly enacted statute); statutes did not confer jurisdiction here |
Key Cases Cited
- Retirement Bd. of Emps.’ Ret. Sys. of City of Providence v. Corrente, 111 A.3d 301 (R.I. 2015) (distinguishing cases where statute grants Superior Court jurisdiction)
- Scolardi v. City of Providence, 751 A.2d 754 (R.I. 2000) (quasi-judicial municipal actions are reviewed by certiorari absent statutory forum)
- Goncalves v. NMU Pension Trust, 818 A.2d 678 (R.I. 2003) (arbitrary-and-capricious standard governs when plan grants administrator discretion)
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (U.S. 1989) (standard for judicial review of ERISA plan interpretation and administrator discretion)
- Eastern Scrap Servs., Inc. v. Harty, 341 A.2d 718 (R.I. 1975) (proper procedure to review quasi-judicial town-council actions is certiorari)
- JMC, LLC v. Town of Cumberland Zoning Bd. of Review, 889 A.2d 169 (R.I. 2005) (municipal quasi-judicial boards must provide findings and reasons)