O'Rourke v. Northern California Electrical Workers Pension Plan, No. 17-17419 (9th Cir. 2019)
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The Ninth Circuit affirmed the district court's grant of summary judgment in an Employee Retirement Income Security Act (ERISA) action challenging the denial of plaintiff's request for early retirement benefits. Plaintiff argued that the Board incorrectly interpreted the Plan to deny his application for benefits.
The panel held that any procedural irregularities in the Board's actions were minor and, at most, the Board's actions weigh only slightly and weakly in favor of holding that an abuse of discretion occurred here. The panel also held that the Board did not abuse its discretion by interpreting "performance of services in any capacity in the Electrical Industry" to include working for the union. In this case, in light of Tapley v. Locals 302 & 612 of Int'l Union of Operating Eng'rs-Emp'rs Const. Indus. Ret. Plan, the panel held that the Board's interpretation did not clearly conflict with the Plan's language; did not render any other Plan provision nugatory; and did not lack a rational nexus to the Plan's purpose. Therefore, the Board's interpretation of the Plan was reasonable.
Court Description: ERISA The panel affirmed the district court’s grant of summary judgment in an ERISA action challenging the denial of plaintiff’s request for early retirement benefits. Plaintiff accrued benefits through a multiemployer ERISA plan during his work as an electrician. When he left this position to work for an electrical workers’ union as an administrator, he sought early retirement benefits from the plan. The plan’s board of trustees decided that plaintiff’s union work fell within the plan’s definition of “prohibited employment,” and so no benefits were due for any month in which he engaged in that work. Reviewing the denial of benefits for an abuse of discretion, the panel held that any procedural irregularities in the actions of the board were minor and, at most, weighed only slightly and weakly in favor of holding that an abuse of discretion occurred. The panel held that the board did not abuse its discretion in interpreting the plan’s definition of prohibited employment to include plaintiff’s union work because the board’s interpretation did not clearly conflict with the plan’s plain language, did not render any other plan provision nugatory, and did not lack a rational nexus to the plan’s purpose. O’ROURKE V. N. CAL. ELEC. WORKERS PENSION 3
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