Gomez v. Ericsson, Inc., No. 15-41479 (5th Cir. 2016)Annotate this Case
Plaintiff filed suit against his former employer, Ericsson, asserting a claim under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Despite filing that federal claim in a federal forum, plaintiff alternatively sought declaratory relief that ERISA did not govern this dispute over the Severance Plans. The district court ruled that ERISA governed the case and later granted summary judgment for Ericsson. The court concluded that Ericsson’s Plans check off most of the factors indicative of ERISA plans, and thus plaintiff's suit seeking to obtain benefits available under them, are governed by the federal statute. On the merits, the court concluded that the district court did not err in ruling as a matter of law that the Plan allowed Ericsson to deny benefits on the ground that plaintiff failed to meet the return of property condition. Given the absence of language entitling plaintiff to severance pay based solely on the release of legal claims, it is not inconsistent with the Plan to impose other conditions reasonably related to the termination of the employment relationship. In this case, a provision requiring the return of property is in line with the overall terms of the Plans, which are aimed at providing severance to those who depart the company on good terms through no fault of their own. Accordingly, the court affirmed the judgment.