Pilger, et al. v. Sweeney, et al., No. 12-2698 (8th Cir. 2013)Annotate this Case
Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001-1461, alleging that defendants violated ERISA when defendants, realizing that they had paid plaintiffs excess retirement benefits, reduced plaintiffs' monthly benefit payments and recouped overpayments through withholding. The court concluded that Count One of the complaint was time-barred; the court rejected plaintiffs' argument that defendants had no authority to either correct or recoup the benefit overpayments where the 2002 plan booklet contained broad language granting defendants such action; because the PPNPF was a defined-benefit plan, plaintiffs could not recover individualized relief in a section 1132(a)(2) claim; and plaintiffs' claim for equitable estoppel under section 1132(a)(3)(B) failed where this claim mirrored Count One's section 1132(a)(1)(B) claim. Accordingly, the court affirmed the district court's grant of summary judgment for defendants.