Stephens v. Alliant Techsystems Corp.
714 F. App'x 841
| 10th Cir. | 2017Background
- Stephens, a participant in Alliant’s defined-benefit plan (serviced by Fidelity), returned monthly retirement checks unopened beginning in 2009 because a Utah QDRO awarded part of his benefits to his ex-wife.
- In late 2014 Fidelity issued a lump-sum check for $152,890.38 and filed a 1099-R with the IRS; Stephens again returned the check and sued, seeking among other relief an order declaring the 1099-R void.
- The magistrate judge denied Stephens’ motions to file a reply and to transfer venue, recommended summary judgment for defendants, and recommended denying leave to amend; the district court adopted those recommendations and overruled Stephens’ objections.
- Stephens appealed and also filed several ancillary motions in the Tenth Circuit (recusal, identifying defendants’ clients, en banc petition, sanctions), all of which the panel denied.
- The panel affirmed: it held the district court lacked authority under the Declaratory Judgment Act to void the 1099-R (a federal tax matter), found no triable fraud or ERISA claim presented, and ruled amendment to add an ERISA challenge to the QDRO would be futile.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction to void the 1099-R / declare no income received | Stephens: court can declare 1099-R "null and void" or state he received no income for tax year 2014 | Defendants: tax-related relief is outside the Declaratory Judgment Act jurisdiction | Court: No jurisdiction to adjudicate federal tax issues or void the 1099-R; dismissal affirmed |
| Motion to file a reply to answer | Stephens: defendants’ answer contained counterclaims so he should be allowed to reply | Defendants: their answer contained admissions/denials and defenses, not counterclaims | Court: No counterclaims in answer; denial of leave to file reply not an abuse of discretion |
| Motion to transfer venue to District of Minnesota | Stephens: transfer is more convenient for witnesses and serves justice | Defendants: Utah is proper forum; plaintiff’s choice and local-law connections favor Utah | Court: Denial proper — plaintiff lives in Utah, relevant events/QDRO are Utah-based, no persuasive showing transfer warranted |
| Motion to amend complaint to challenge QDRO under ERISA | Stephens: proposed amendment alleges QDRO violates ERISA and seeks modified QDRO relief | Defendants: amendment would be futile because state court reserved modification power and QDROs fall outside ERISA preemption; domestic-relations exception applies | Court: Amendment futile; denial affirmed |
Key Cases Cited
- Bryce v. Episcopal Church in the Diocese of Colo., 289 F.3d 648 (10th Cir. 2002) (recusal standard: whether a reasonable person would question judge’s impartiality)
- Sterling Consulting Corp. v. United States, 245 F.3d 1161 (10th Cir. 2001) (district courts cannot determine a party’s tax liabilities via declaratory relief)
- Palace Expl. Co. v. Petroleum Dev. Co., 316 F.3d 1110 (10th Cir. 2003) (standard of review and deference for §1404(a) venue-transfer decisions)
- Emp’rs Mut. Cas. Co. v. Bartile Roofs, Inc., 618 F.3d 1153 (10th Cir. 2010) (forum deference to plaintiff’s choice and local-law considerations in transfer analysis)
- Leathers v. Leathers, 856 F.3d 729 (10th Cir. 2017) (domestic-relations exception bars federal courts from issuing or modifying divorce decrees)
- Full Life Hospice, LLC v. Sebelius, 709 F.3d 1012 (10th Cir. 2013) (leave to amend may be denied where proposed amendment is futile)
- Jones v. Norton, 809 F.3d 564 (10th Cir. 2015) (futility review of denial of leave to amend is de novo)