Robert Buchanan v. Delphi Corporation
597 F. App'x 305
6th Cir.2015Background
- Plaintiffs are retired autoworkers who worked for GM, Bosch, and Delphi, pursued under the SAP, a pre-retirement program linked to reaching 30 years of service.
- SAP promised continued wages and credited service toward pensions until retirement at 30 years, with benefits later paid by Delphi or GM Pension Plans.
- In 2008 Delphi letters indicated a dispute over combined service for pension eligibility and a pro-rata ‘30 and out’ pension involving all three companies.
- GM later transferred Delphi assets to the GM Pension Plan, stating pensions would be paid from GM and total benefits would not change, but later reduced benefits by excluding Bosch service.
- Plaintiffs allege SAP misrepresentations and seek ERISA relief for alleged SAP violations, despite not alleging a GM Plan violation.
- District court granted GM judgment on the pleadings as to all ERISA claims; the appeal challenges that ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the SAP an ERISA plan? | SAP constitutes an ERISA plan providing retirement benefits. | SAP is not an ERISA plan because it does not provide retirement income itself; benefits come from GM/Delphi plans. | SAP is not an ERISA pension plan; ERISA claims fail. |
| Are Plaintiffs’ claims rooted in the SAP rather than GM's Pension Plan? | Plaintiffs alleged violations of the SAP and its impact on their pension. | Plaintiffs fail to plead ERISA violations of the GM Pension Plan itself and rely on SAP as standalone. | Claims are rooted in the SAP and fail as ERPISA violations. |
| Do ERISA claims fail because SAP is not an ERISA plan? | ERISA applies to any plan-like arrangement including SAP. | Since SAP is not an ERISA plan, ERISA claims fail as a matter of law. | ERISA claims fail. |
| Was exhaustion of administrative remedies required under GM’s plan? | Administrative exhaustion not required or plaintiffs exhausted remedies under SAP. | Administrative exhaustion is required to determine fiduciary actions and benefits under the GM plan. | Exhaustion required; dismissal affirmed pending exhaustion record. |
| Should the district court’s judgment on the pleadings be affirmed based on ERISA plan status and exhaustion? | ERSA claims should proceed because SAP/MG interactions merit relief. | Affirm dismissal since SAP not ERISA and exhaustion absent. | Judgment affirmed. |
Key Cases Cited
- Miller v. Metro. Life Ins. Co., 925 F.2d 979 (6th Cir.1991) (exhaustion of administrative remedies in ERISA actions)
- Costantino v. TRW, Inc., 13 F.3d 969 (6th Cir.1994) (policies promoting administrative exhaustion under ERISA)
- Makar v. Health Care Corp. of the Mich-Atlantic (CareFirst), 872 F.2d 80 (4th Cir.1989) (explanation of exhaustion purposes in ERISA statutes)
- Amato v. Bernard, 618 F.2d 559 (9th Cir.1980) (ERISA administrative exhaustion considerations)
- Sensations, Inc. v. City of Grand Rapids, 526 F.3d 291 (6th Cir.2008) (liberal pleading construction and ERISA context limitations)
- League of United Latin Am. Citizens v. Bredesen, 500 F.3d 523 (6th Cir.2007) (ERISA claim handling and administrative process considerations)