Williams v. Rohm and Haas Pension Plan, 658 F.3d 629

This ERISA class action challenged lump-sum distributions from Rohm and Haas Pension Plan for missing COLA adjustments.
District court found liability; on remand the Plan argued damages and statute-of-limitations issues but settlement was reached before final damages ruling.
Proposed settlement would pay early retirees roughly 3.5% of original lump sums, with COLA-based scenarios affecting some awards.
Adamski Objectors claimed discrimination and demanded separate counsel; Jackson objected to release of his unrelated claims and sought an opt-out.
District court approved the settlement and awarded $43.5 million in attorney’s fees, which objectors challenged on methodology.
Seventh Circuit affirmed both the settlement approval and the attorney’s-fees award after review of the district court’s discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether settlement approval was fair and reasonable	Adamski objectors argued net value to the class was inadequately analyzed.	District court adequately assessed early retirees' claims value and risks, with substantial settlement value.	Settlement approved; court did not abuse discretion.
Whether Jackson could opt out of the settlement	Opt-out requested to preserve claims against the disability plan; release would overreach.	Opt-out is inappropriate in ERISA class actions and the release limited to plan claims.	District court did not err in denying opt-out; settlement approved.

Synfuel Techs., Inc. v. DHL Express (USA), Inc., 463 F.3d 646 (7th Cir. 2006) (district court acts as fiduciary; need for fair, adequate scrutiny)
Mirfasihi v. Fleet Mortg. Corp., 450 F.3d 745 (7th Cir. 2006) (warning signs in settlement; court must assess value to class)
Reynolds v. Beneficial Nat'l Bank, 288 F.3d 277 (7th Cir. 2002) (settlement considerations in class actions)
In re Synthroid Mktg. Litig., 264 F.3d 712 (7th Cir. 2001) (ex ante bargain and market-rate fee practice)
Taubenfeld v. AON Corp., 415 F.3d 597 (7th Cir. 2005) (evidence-based approach to determining fee market)
McCarter v. Ret. Plan for the Dist. Mgrs of Am. Family Ins. Grp., 540 F.3d 649 (7th Cir. 2008) (regarding the scope of ERISA plan regulations and holdings)
Laurenzano v. BCBS of Mass., Inc. Ret. Income Trust, 191 F.Supp.2d 223 (D. Mass. 2002) (fee awards in similar ERISA matters; market-rate context)
In re Amino Acid Lysine Antitrust Litig., 918 F. Supp. 1190 (N.D. Ill. 1996) (class counsel auction evidence; criticized in Synthroid context)