Ingram v. Terminal Railroad Ass'n, No. 14-3589 (8th Cir. 2016)Annotate this Case
Plaintiff filed suit under section 502(a)(1)(B) of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)(B), alleging that the Plan erroneously determined his pension benefits. The district court granted summary judgment to the Plan. The court concluded that none of the conflicts of interest and procedural irregularities alleged by plaintiff “caused a serious breach of the plan administrator’s fiduciary duty” which warranted departure from the abuse-of-discretion standard of review. In this case, the district court correctly reviewed the decision of the Plan administrator for an abuse of discretion; substantial evidence supports the Plan administrator’s decision to exclude a 2006 sign-on bonus from pension-qualifying earnings and there was no abuse of discretion; and the Plan administrator’s interpretation of offsets for retirement benefits was reasonable because it was not inconsistent with Plan language, was consistent with Plan goals and ERISA, and rationally construed the offset so that the Normal Retirement Benefit under the Plan does not vary because of the form of payment chosen under another plan. Accordingly, the court affirmed the judgment.