Schumacher v. AK Steel Corp. Retirement Accumulation Pension Plan
711 F.3d 675
| 6th Cir. | 2013Background
- Ninety-two AK Steel employees, previously excluded from the West v. AK Steel class, pursued ERISA whipsaw benefits under RAPP via Schumacher and a class.
- Many signed severance agreements during 2003 layoffs, which broadly released claims but did not mention ERISA or pension rights.
- West outcome found whipsaw damages were due; Schumacher class seeks similar relief for benefits not yet accrued at signing.
- District court certified class, awarded unpaid benefits ($3,010,060) and pre-judgment interest at 0.12%, and later rulings addressed limitations and liability.
- On appeal, the Sixth Circuit reversed the pre-judgment-interest rate but affirmed other judgments, remanding for a just interest award.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1658(a) applies to the class claims | Class argues § 1658(a) does not apply to ERISA whipsaw claims. | AK Steel contends the catch-all § 1658(a) governs timing. | § 1658(a) does not apply to the Class's claims. |
| Whether the district court abused its discretion in class certification | Schumacher class presents common questions about releases and ERISA waivers. | Defendants argue releases require individualized review, defeating common questions. | No abuse; common legal questions predominate; certification affirmed. |
| Whether the district court erred in granting partial summary judgment on liability | Claims arise from the same whipsaw issue as West; severance agreements did not release future ERISA claims. | Severance Agreements released potential future claims; liability barred. | Correct to hold that severance agreements did not bar future ERISA claims; liability affirmed. |
| Whether the pre-judgment interest rate was properly awarded | District rate under § 1961(a) failed to balance remedial goals and avoid unjust enrichment. | Statutory rate 0.12% was proper and consistent with the West ruling. | Remand to fashion a just pre-judgment-interest award; 0.12% reversed. |
Key Cases Cited
- McCormick v. Miami Univ., 693 F.3d 654 (6th Cir. 2012) (test for applying § 1658 when post-1990 amendments confer a federal cause of action)
- Jones v. R.R. Donnelley & Sons Co., 541 U.S. 369 (S. Ct. 2004) (determines when § 1658 applies to post-1990 amendments and new rights)
- Santino v. Provident Life & Accident Ins. Co., 276 F.3d 772 (6th Cir. 2001) (ERISA claims limitations governed by most analogous state statute)
- Rybarczyk v. TRW, Inc., 235 F.3d 975 (6th Cir. 2000) (abuse of discretion in pre-judgment interest when not case-specific)
- Ford v. Uniroyal, 154 F.3d 613 (6th Cir. 1998) (considerations for remedial pre-judgment interest amount)
- Goepfert v. Trustmark Ins. Co., 541 F. Supp. 2d 1052 (W.D. Wis. 2008) (explicit ERISA references in releases affect waiver of future claims)