State v. Pack
2012 ND 48
| N.D. | 2012Background
- Bensons, retirees from NSP-derived Minot Telephone, sue SRT for post-retirement health benefits continuation.
- NSP sold Minot Telephone to Rochester (1991 asset purchase); Rochester later became SRT.
- 1991 CBA between NSP and union provided medical benefits through 1993; SRT assumed it.
- SRT continued benefits until 2009, then terminated benefits at Medicare eligibility.
- District court granted summary judgment; held LMRA/ERISA preempt federal review; decline state-law remedies.
- Issue center: whether federal law preempts and whether any separate contract or asset-purchase liability supports continued benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the claim preempted by federal law? | Bensons rely on a separate contract. | Claim arises from the 1991 CBA; preempted by LMRA/ERISA. | Yes; ERISA/LMRA preempt the state claim. |
| Did Rochester/SRT assume liability via asset purchase or separate contract? | There existed a separate contract creating lifetime benefits. | No separate agreement; liability limited to assets agreed in NSP-Rochester pact. | No evidence of separate contract; no assumed liability beyond provided assets. |
| Can equitable estoppel salvage the claim? | Detrimental reliance on continued coverage. | ERISA preempts estoppel; no facts show misrepresentation. | Preempted; also insufficient state-law estoppel facts. |
| Do the 1991 terms vest post-retirement benefits for life? | Language implies lifetime vesting. | Expression of expiration in 1993; no vesting language. | No vesting; benefits not guaranteed after 1993. |
Key Cases Cited
- Bowen v. United States Postal Serv., 459 U.S. 212 (1983) (federal labor-law preemption and scope of LMRA)
- Textile Workers Union v. Lincoln Mills, 353 U.S. 448 (1957) (federal common law governing labor contracts)
- Pilot Life Ins. v. Dedeaux, 481 U.S. 41 (1987) (ERISA preemption scope in benefit plans)
- Aetna Health Inc. v. Davila, 542 U.S. 200 (2004) (ERISA preemption broad, uniform regulatory regime)
- Curtiss-Wright Corp. v. Schoonejongen, 514 U.S. 73 (1995) (ERISA welfare plans can be modified or terminated)
- Litton Fin. Printing Div., a Div. of Litton Business Sys., Inc. v. NLRB, 501 U.S. 190 (1991) (contract duration and surviving obligations)
- Allis-Chalmers Corp. v. Lueck, 471 U.S. 202 (1985) (state-law claims duplicating ERISA remedies pre-empted)