Strumsky v. Washington Post Company
842 F. Supp. 2d 215
D.D.C.2012Background
- Strumsky worked as a machinist for the Washington Post from 1987 to July 15, 2009 and participated in the Craft Pension Plan.
- In 2009, the VRIP offered retirement benefits to eligible employees, with a June 30, 2009 enrollment deadline.
- Plaintiff allegedly contacted Post to enroll before the deadline but did not submit enrollment documentation by June 30, 2009.
- After the deadline, Strumsky sought enrollment and was told he had missed it; he filed suit in DC Superior Court on September 28, 2010 seeking VRIP benefits and alleging ERISA and three state-law theories.
- Post removed the case to federal court and moved to dismiss under Rule 12(b)(6); the court granted the motion and dismissed all claims with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether VRIP benefits fall within ERISA pension plan coverage | Strumsky argues VRIP constitutes ERISA pension benefits. | Post contends the VRIP benefits are ERISA-covered pension benefits applicable to the Craft Plan. | VRIP benefits are ERISA pension benefits. |
| Whether Counts II–IV are preempted by ERISA | Counts II–IV should not be preempted since they seek relief under state law. | Counts II–IV duplicate or prempt ERISA's civil enforcement remedy for benefits. | Counts II–IV are preempted by ERISA and dismissed. |
| Whether Count I survives given plaintiff voluntarily dismissed ERISA claim | ERISA claim should proceed to obtain VRIP benefits. | ERISA claim is withdrawn/voluntarily dismissed; remaining claims fail independently. | ERISA claim dismissed; court proceeds to analyze remaining claims for preemption. |
| Whether the remaining claims may be maintained through supplemental jurisdiction | State-law claims could be pursued notwithstanding ERISA preemption. | ERISA preemption bars state-law claims; no supplemental jurisdiction over them. | Counts II–IV are preempted and dismissed; no viable state-law claims remain. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading standard requires plausible claim)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility pleading required)
- Aetna Health, Inc. v. Davila, 542 U.S. 200 (U.S. 2004) (ERISA preemption of state-law claims related to plan)
- Pilot Life Ins. Co. v. Dedeaux, 481 U.S. 41 (U.S. 1987) (ERISA preemption framework)
- In re Ingersoll-Rand Co. v. McClendon, 498 U.S. 133 (U.S. 1990) (definition of what constitutes a claim that 'relates to' an ERISA plan)