Sturge v. Northwest Airlines, Inc., No. 10-2813 (8th Cir. 2011)
Annotate this CaseAppellant was terminated for cause from his employment with Northwest Airlines shortly after he was arrested for possession of marijuana. At the same time, appellant had pending with Northwest a request for disability retirement benefits. Northwest later granted appellant's request, but he was ineligible for certain retirement benefits as a result of the termination. Appellant sued Northwest, claiming that the termination violated section 510 of the Employment Retirement Income Security Act (ERISA), 29 U.S.C. 1140. The district court denied Northwest's motion to dismiss for lack of subject-matter jurisdiction, but granted its motion for summary judgment. The court held that the district court properly exercised jurisdiction over the case where appellant's claim did not require an interpretation of a collectively bargained agreement. The court also held that appellant failed to show a causal connection between his termination and his application for disability retirement benefits. The court rejected appellant's remaining arguments. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil Case - ERISA. Terminated employee who later received disability retirement claimed a denial of certain benefits under ERISA. District court did not err in denying motion to dismiss for lack of subject matter jurisdiction because the claims are independent of an interpretation or application of any collective bargaining agreement. Grant of summary judgment to employer is affirmed, as Sturge did not prove termination was causally connected to his application for disability retirement and Sturge did not show comparator evidence represented a factual dispute because other employee was not similarly situated.
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