Rodrigues v. United Public Workers, AFSCME Local 646Annotate this Case
Petitioner, the former State director of United Public Workers, AFSCME Local 646, FL-CIO (UPW) and a former administrator of UPW’s Mutual Aid Fund trust (MAF), was held liable by a federal district court for negligently making loans under ERISA and thus breaching his fiduciary duties to the MAF. The court entered judgment against Petitioner in the amount of $850,000. Petitioner filed a complaint in the circuit court requesting that UPW indemnify him for the $850,000 on the grounds that his liability to the MAF arose from actions he took solely in his capacity as agent for UPW and/or that UPW ratified his actions. The circuit court granted summary judgment for UPW. The Intermediate Court of Appeals (ICA) affirmed, concluding that because Petitioner was responsible for his own conduct, he was not entitled to be indemnified for his negligent acts as a matter of law. Petitioner requested certiorari, claiming that the ICA erred in concluding that his negligence claim defeated his indemnification claim as a matter of law. The Supreme Court denied certiorari without reaching this issue, holding that ERISA preemption, not Petitioner’s negligence, defeated Petitioner’s state indemnity claims against UPW as a matter of law.