William Pilger v. William Sweeney
725 F.3d 922
| 8th Cir. | 2013Background
- Thirteen retired Local 212 plumbers sue the PPNPF and trustees for ERISA benefits and recoupment actions.
- PPNPF is a defined-benefit pension plan funded by multiple employers and managed by its Board and Administrator.
- 1999–2000, Defendants set Local 212 past-service rate at $1.05/hour (not $1.95), while 66/125 were raised to $1.95.
- Plaintiffs’ benefits were calculated using $1.95/hour, leading to overpayments and inflated monthly benefits.
- In 2009 Defendants identified the mistake, reduced benefits, and began withholding 25% of benefits to recover overpayments; suit filed February 15, 2011.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Count One is time-barred under the limitations period | Shaw applies; denial occurred 2000; suit filed 2011. | Iowa 10-year breach-of-contract period applies; timely denial in 1999–2000. | Yes; Count One is time-barred. |
| Whether Defendants had authority to correct and recoup overpayments | Plan booklet did not authorize remedial actions. | 2002 plan booklet grants discretion to take remedial action. | Count One’s corrective/recoupment aspect is upheld; authority shown. |
| Whether Count Two (breach of fiduciary duty) is recoverable for benefits to individuals | Fiduciaries must pay benefits to Plaintiffs based on $1.95/hour. | Defined-benefit plan relief is for the plan as a whole, not individuals. | Count Two fails; §1132(a)(2) relief to plan, not individuals. |
| Whether Count Three (equitable estoppel) is duplicitous of Count One | Estoppel to prevent decreasing benefits and recoupment; relies on misstatements. | Remedy sought is identical to Count One; not allowed under law. | Count Three fails; duplicative of Count One under Antolik/Varity. |
Key Cases Cited
- Shaw v. McFarland Clinic, P.C., 363 F.3d 744 (8th Cir. 2004) (borrows statute of limitations for ERISA §1132(a)(1)(B))
- Union Pac. R.R. Co. v. Beckham, 138 F.3d 325 (8th Cir. 1998) (determines limitations start when claim denied)
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989) (fiduciary duties analyzed under ERISA)
- Midgett v. Wash. Grp. Int’l Long Term Disability Plan, 561 F.3d 887 (8th Cir. 2009) (prudence/loyalty duties in ERISA context)
- LaRue v. DeWolff, Boberg & Assocs., Inc., 552 U.S. 248 (U.S. 2008) (relates to plan benefit rights for defined-benefit plans)
- Antolik v. Saks, Inc., 463 F.3d 796 (8th Cir. 2006) (equitable estoppel barred where §1132(a)(1)(B) provides adequate relief)
- Varity Corp. v. Howe, 516 U.S. 489 (1996) (limits duplicative ERISA remedies)
- Conley v. Pitney Bowes, 176 F.3d 1044 (8th Cir. 1999) (application of ERISA remedies)
- Korotynska v. Metro. Life Ins. Co., 474 F.3d 101 (4th Cir. 2006) (cited regarding duplicative remedies)