Niebauer v. Crane & Co., Inc., No. 14-2059 (1st Cir. 2015)Annotate this Case
Plaintiff brought this complaint under the Employee Retirement Income Security Act (ERISA), alleging (1) the administrator of his former employer’s executive severance plan denied him severance benefits after improperly determining that he had voluntarily retired from his position, and (2) his former employer impermissibly interfered with his protected rights under the plan. The district court granted summary judgment for Defendants on both counts. The First Circuit (1) affirmed the district court’s judgment with regard to the plan administrator’s decision to deny Plaintiff’s claim for benefits, holding the decision was both supported by substantial evidence and procedurally proper; but (2) vacated the district court’s judgment as to the interference claim, holding that the district court relied on the incorrect standard in assessing the interference claim. Remanded for application of the appropriate standard of review.