Knowlton v. Anheuser-Busch, No. 15-3538 (8th Cir. 2017)
Annotate this CasePlaintiff and eight others filed a class action against Anheuser-Busch under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Plaintiffs are participants in the Anheuser-Busch salaried employee pension plan and claim that they are entitled to enhanced pension benefits. At issue is the interpretation of Section 19.11(f) of the plan. Determining that it has jurisdiction over the appeal, the court concluded that Section 19.11(f) is unambiguous and agreed with the district court's adoption of the reasoning in the Sixth Circuit's case, Adams v. Anheuser-Busch Cos., that Section 19.11(f) entitled plaintiffs to enhanced benefits. Although the court affirmed on the merits, the court agreed with plaintiffs that the decision still must be reversed and remanded because the district court failed to make individual calculations of enhanced benefits owed to individual members of the class. Therefore, the court reversed and remanded with instructions to reconsider plaintiffs' prayer for relief and, to the extent requested and provable, calculate and award the benefits owed to plaintiffs by applying Section 19.11(f). The court noted that, upon remand, the district court may reconsider whether certain records will assist in its calculation of the requested benefits.
Court Description: Riley, Author, with Murphy and Smith, Circuit Judges] Civil case - ERISA. In action by former Sea World employees claiming they were entitled to enhanced pension benefits under the defendant's salaried employee pension plan, the district court correctly determined that Section 19.11(f) of the plan entitled plaintiffs to enhanced pension benefit; this decision is in accord with the Sixth Circuit's interpretation of the provision in Adams v. Anheuser-Busch Cos., 758 F.3d 743 (6th Cir. 2014); with respect to plaintiff's cross-appeal, asserting the district court erred by failing to make individual calculations of the enhanced benefits owed to individual members of the class, the district court erred in concluding that plaintiff's complaint sought only a declaration that Section 19.11(f) applied, as their complaint made a sufficient request for an actual award of certain benefits with the application of the enhanced benefit; therefore, the matter of the calculation of benefits is reversed and remanded with instructions to reconsider the plaintiff's prayer for relief and, to the extent requested and provable, calculate and award the benefits owed to plaintiffs by applying Section 19.11(f); finally, on remand, the district court should reconsider whether certain records concerning the absentee class members will assist in its calculation of the requested benefits.
The court issued a subsequent related opinion or order on February 23, 2017.
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