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firestone tire and rubber co v bruch

Stay up-to-date with FindLaw's newsletter for legal professionals. I think that, properly read, the definition of "participant" embraces those whose benefits have vested, and those who (by reason of current or former employment) have some potential to receive the vesting of benefits in the future, but not those who have a good argument that benefits have vested even though they have not. at 534. (A) for the relief provided for in [ 1132(c)], [and] (B) to recover benefits due to him under the terms of his plan." 29942 (1974) (remarks of Sen. Javits)). 1988). 87-1054. See, e.g., 29 U.S.C. Id., at 138 (citing cases). An Insurance Company's Conflict of Interest. Since, however, no employer The administrator may make a reasonable charge to cover the cost of furnishing such complete copies. The words of a plan may speak clearly, but they may also leave gaps. Given this language and history, we have held that courts are to develop a "federal common law of rights and obligations under ERISA-regulated plans." 1002(8). Footnote * As they do with contractual provisions, courts construe terms in trust agreements without deferring to either party's interpretation. But the provisions relied upon so heavily by Firestone do not characterize a fiduciary as one who exercises entirely discretionary authority or control. Complaint §§ 87-94, App. We likewise express no views as to whether respondents were "participants" with respect to the benefit plans about which they sought information. enormously complex and detailed statute,” Mertens v. Hewitt Associates, 508 U. S. 248, 262 (1993), and the plans that administrators must construe can be lengthy and complicated. U.S. 41, 52 1033, 1037-1039 (1985). Firestone and its amici also assert that a de novo standard would contravene the spirit of ERISA because it would impose much higher administrative and litigation costs, and therefore discourage employers from creating benefit plans. Since the Court of Appeals did not attempt to determine whether respondents were "participants" with respect to the plans about which they sought information, it must do so on remand. 463 U.S. 101, 113] 489 U. S. 110-115. U.S. 101, 111] In addition, Firestone denied the requests for information concerning benefits under the three plans. 1614 et al. The action was based on 1132(a)(1), which provides that a "civil action may be brought . No. Nevertheless, Firestone maintains that congressional action after the passage of ERISA indicates that Congress intended ERISA claims to be reviewed under the arbitrary and capricious standard. A fiduciary has "authority to control and manage the operation and administration of the plan," § 1102(a)(1), and must provide a "full and fair review" of claim denials, § 1133(2). The action was based on § 1132(a)(1), which provides that a, "civil action may be brought . In Count VII, respondents alleged that they were entitled to damages under § 1132(c) because Firestone had breached its reporting obligations under § 1025(a). Contacting Justia or any attorney through this site, via web form, email, or otherwise, does not create an attorney-client relationship. U.S. 824, 837 Respondents' action asserting that they were entitled to benefits because the sale of Firestone's Plastics Division constituted a "reduction in work force" within the meaning of the termination pay plan was based on the authority of 1132(a) (1)(B). The dispute in this case therefore centers on the definition of the term "participant," which is found in § 1002(7): "The term 'participant' means any employee or former employee of an employer, or any member or former member of an employee organization, who is or may become eligible to receive a benefit of any type from an employee benefit plan which covers employees of such employer or members of such organization, or whose beneficiaries may be eligible to receive any such benefit. That provision allows a suit to recover benefits due under the plan, to enforce rights under the terms of the plan, and to obtain a declaratory judgment of future entitlement to benefits under the provisions of the plan contract. (1985). Respondent Bruch . Pe-titioners have alleged staggering misconduct: abject im-prudence and unadorned self … . The Secretary [of Labor] may by regulation prescribe the maximum amount which will constitute a reasonable charge under the preceding sentence. and their families and dependents." 1002(21) (A)(i). U.S. 85, 90 See generally 29 U.S.C. Firestone Tire & Rubber Co. v. Bruch,9 the Supreme Court di-rected courts to review suits for benefits under a de novo stan-dard unless the plan's administrator has discretion to make benefit decisions.10 Since Bruch, federal circuits have split over the appropriate evidentiary scope of de novo review in ERISA benefit cases. JUSTICE O'CONNOR delivered the opinion of the Court. Consistent with established principles of trust law, we hold that a denial of benefits challenged under § 1132(a)(1)(B) is to be reviewed under a de novo standard unless the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan. Under ERISA a plan participant is "any employee or former employee . , n. 26 (1983) ("`[A] body of Federal substantive law will be developed by the courts to deal with issues involving rights and obligations under private welfare and pension plans'") (quoting 129 Cong. U.S. 716, 724 U.S. 986 Ante, at 117. Syllabus. Co. v. Russell, The terms of trusts created by written instruments are "determined by the provisions of the instrument as interpreted in light of all the circumstances and such other evidence of the intention of the settlor with respect to the trust as is not inadmissible." 40. [489 JUSTICE O'CONNOR delivered the opinion of the Court. 479 1002(7) ("participant"), 1002(8) ("beneficiary"), 1002(21)(A) ("fiduciary"), 1103(a) ("trustee"), 1104 ("fiduciary duties"). Thus, the raison d'etre for the LMRA arbitrary and capricious standard - the need for a jurisdictional basis in suits against trustees - is not present in ERISA. IV), which provides that, "[a]ny administrator . Cf. See also G. Bogert & G. Bogert, Law of Trusts and Trustees 560, pp. by looking to the terms of the plan and other manifestations of the parties' intent. . National Retirement Fund, 754 F.2d 473, 476 (CA2 1985), or former employees who "have . See Van Boxel v. Journal Co. Employees' Pension Trust, 836 F.2d 1048, 1052 (CA7 1987) ("[W]hen a plan provision as interpreted had the effect of denying an application for benefits unreasonably, or as it came to be said, arbitrarily and capriciously, courts would hold that the plan as structured' was not for the sole and exclusive benefit of the employees, so that the denial. 455 Google Chrome, Pp. For the reasons set forth above, the decision of the Court of Appeals is affirmed in part and reversed in part, and the case is remanded for proceedings consistent with this opinion. . 87-1054 Argued: November 30, 1988 Decided: February 21, 1989. See generally Pilot Life Ins. Supreme Court of United States. Since, however, no employer. ERISA's legislative history confirms that the Act's fiduciary responsibility provisions, 29 U.S.C. . O'CONNOR, J., delivered the opinion for a unanimous Court with respect to Parts I and II, and the opinion of the Court with respect to Part III, in which REHNQUIST, C. J., and BRENNAN, WHITE, MARSHALL, BLACKMUN, STEVENS, and KENNEDY, JJ., joined. To say that a "participant" is any person who claims to be one begs the question of who is a "participant" and renders the definition set forth in § 1002(7) superfluous. The trust law de novo standard of review is consistent with the judicial interpretation of employee benefit plans prior to the enactment of ERISA. See, e.g., Struble v. New Jersey Brewery Employees' Welfare Trust Fund, 732 F.2d 325, 333 (CA3 1984); Bayles v. Central States, Southeast and Southwest Areas Pension Fund, 602 F.2d 97, 99-100, and n. 3 (CA5 1979). In relevant part, 29 U.S.C. See Brief for Petitioners 19-20. If a plan gives discretion to such an official, however, the conflict must be weighed as a factor in determining whether there is an abuse of discretion. ", When Firestone did not comply with their request for information, respondents sought damages under 29 U.S.C. 519 (ED Pa. 1986). denied, 479 U.S. 916 (1986). 87-1054. 24-25; Reply Brief for Petitioners 7, n. 2; Brief for United States as Amicus Curiae 14-15, n. 11. IV). § 1132(c)(1)(B) (1982 ed., Supp. David M. Silberman argued the cause for respondents. Firestone Tire & Rubber Co. v. Bruch, 489 U. S. 101, 113 (1989). 94.   U.S. 101, 115] Media. ERISA was enacted "to promote the interests of employees and their beneficiaries in employee benefit plans," Shaw v. Delta Airlines, Inc., 463 U. S. 85, 463 U. S. 90 (1983), and "to protect contractually defined benefits," Massachusetts Mutual Life Ins. See also Central States, Southeast and Southwest Areas Pension Fund v. Central Transport, Inc., supra, at 568 ("The trustees' determination that the trust documents authorize their access to records here in dispute has significant weight, for the trust agreement explicitly provides that `any construction [of the agreement's provisions] adopted by the Trustees in good faith shall be binding upon the Union, Employees, and Employers'"). 640 F. Supp. FIRESTONE TIRE & RUBBER CO. Argued Nov. 30, 1988. 98-104. Justia makes no guarantees or warranties that the annotations are accurate or reflect the current state of law, and no annotation is intended to be, nor should it be construed as, legal advice. 4, 11 N. E. 2d 878 (1937). See also G. Bogert & G. Bogert, Law of Trusts and Trustees § 560, pp.193-208 (2d. Christopher G. Mackaronis and Cathy Ventrell-Monsees filed a brief for the American Association of Retired Persons as amicus curiae. Firestone Tire & Rubber Co. v. Bruch, 489 U.S.110, 115, the Court reasoned that the employer and ERISA administrator could agree on a more deferential standard of review. With respect to Count VII, the Court of Appeals held that the right to request and receive information about an employee benefit plan "most sensibly extend[s] both to people who are in fact entitled to a benefit under the plan and to those who claim to be but in fact are not." If the plan did not give the employer or administrator discretionary or final authority to construe uncertain terms, the court reviewed the employee's claim as it would have any other contract claim --. Co. v. Dedeaux, 481 U. S. 41, 481 U. S. 52-57 (1987) (describing scope of § 1132(a)). . National Retirement Fund, 754 F.2d 473, 476 (CA2 1985), or former employees who "have . 2d 866 (Del. The Court holds that a person with a colorable claim is one who "may become eligible' for benefits" within the meaning of the statutory definition of "participant," because, it reasons, such a claim raises the possibility that "he or she will prevail in a suit for benefits." National Retirement Fund, supra, at 476. FIRESTONE TIRE & RUBBER CO. v. BRUCH(1989). Since the Supreme Court’s decision in Firestone Tire and Rubber Co. v. Bruch, 489 U.S. 101 (1989), federal courts have reviewed an ERISA health plan’s denial of benefits for arbitrariness and capriciousness, so long as the plan explicitly grants discretionary authority to an administrator or other fiduciary to render benefit decisions. Actions challenging an employer's denial of benefits before the enactment of ERISA were governed by principles of contract law. sensible enough to consult the law would be senseless enough to take that risk, giving the term its defined meaning would produce precisely the same incentive for disclosure as the Court's opinion. Because the bill was never enacted, Firestone asserts that we should conclude that Congress was satisfied with the arbitrary and capricious standard. The District Court granted Firestone's motion for summary judgment. In light of Congress' general intent to incorporate much of LMRA fiduciary law into ERISA, see NLRB v. Amax Coal Co., 453 U. S. 322, 453 U. S. 32 (1981), and because ERISA, like the LMRA, imposes a duty of loyalty on fiduciaries and plan administrators, Firestone argues that the LMRA arbitrary and capricious standard should apply to ERISA actions. [2] "The plan is subject to the procedural protections … See Van Boxel v. Journal Co. Employees' Pension Trust, 836 F.2d 1048, 1052 (CA7 1987) ("[W]hen a plan provision as interpreted had the effect of denying an application for benefits unreasonably, or as it came to be said, arbitrarily and capriciously, courts would hold that the plan as `structured' was not for the sole and exclusive benefit of the employees, so that the denial of of benefits violated [§ 186(c)])." Syllabus ; View Case ; Petitioner Firestone Tire & Rubber Company . U.S. 101, 121] . (1980), ERISA does not set out the appropriate standard of review for actions under 1132(a)(1)(B) challenging benefit eligibility determinations. A beneficiary is "a person designated by a participant, or by the terms of an employee benefit plan, who is or may become entitled to a benefit thereunder." Recently the Eighth Circuit Court of Appeals affirmed the trial court's summary judgment order in a similar case Lakey v. Remington Arms, 874 F.2d 541 (8th Cir.1989). It noted, however, that the arbitrary and capricious standard had been softened in cases where fiduciaries and administrators had some bias or adverse interest. FIRESTONE TIRE & RUBBER CO. v. BRUCH Syllabus FIRESTONE TIRE & RUBBER CO. Federal courts adopted the arbitrary and capricious standard both as a standard of review and, more importantly, as a means of asserting jurisdiction over suits under § 186(c) by beneficiaries of LMRA plans who were denied benefits by trustees. To fill this gap, federal courts have adopted the arbitrary and capricious standard developed under 61 Stat. See §§ 1024(b)(4), 1025(a). 829, as amended, 29 U.S.C. Several respondents also sought information about their benefits under all three plans pursuant to 1024(b)(4)'s disclosure requirements, but Firestone denied those requests on the ground that respondents were no longer plan "participants" entitled to information under ERISA. 157, 29 U.S.C. See also United States v. Mason, 412 U. S. 391, 412 U. S. 399 (1973). ERISA defines a fiduciary as one who, "exercises any discretionary authority or discretionary control respecting management of [a] plan or exercises any authority or control respecting management or disposition of its assets.". United States v. Price, v. Richard BRUCH, etc., et al. See, e.g., Jung v. FMC Corp., 755 F.2d 708, 711-712 (CA9 1985) (where "the employer's denial of benefits to a class avoids a very considerable outlay [by the employer], the reviewing court should consider that fact in applying the arbitrary and capricious standard of review," and "[l]ess deference should be given to the trustee's decision"). Co. v. Russell, 473 U.S. at 473 U. S. 148. The terms of trusts created by written instruments are, "determined by the provisions of the instrument as interpreted in light of all the circumstances and such other evidence of the intention of the settlor with respect to the trust as is not inadmissible.". After Firestone sold its Plastics Division to Occidental Petroleum Co. (Occidental), respondents, Plastics Division employees who were rehired by Occidental, sought severance benefits under the termination pay plan, but Firestone denied their requests on the ground that there had not been a "reduction in workforce" that would authorize benefits under the plan's terms. See, e. g., 29 U.S.C. [489 489 U.S. 101. § 1002(16)(A)(ii), and fiduciary, § 1002(21)(A), of each of these "unfunded" plans. . Thus, the raison d'etre for the LMRA arbitrary and capricious standard -- the need for a jurisdictional basis in suits against trustees -- is not present in ERISA. We do not think that this bit of legislative inaction carries the day for Firestone. To say that a "participant" is any person who claims to be one begs the question of who is a "participant" and renders the definition set forth in 1002(7) superfluous. Id., at 153. § 559, at 169-171. 87-1054. But other settled principles of trust law, which point to de novo review of benefit eligibility determinations based on plan interpretations, belie this contention. With respect to Count I, the District Court held that Firestone had satisfied its fiduciary duty under ERISA because its decision not to pay severance benefits to respondents under the termination, pay plan was not arbitrary or capricious. ed.1980). Rather, one is eligible whether or not he has yet been adjudicated to be -- and similarly one can become eligible before he is adjudicated to be. 94. ERISA's disclosure provisions. BRUCH v. FIRESTONE TIRE AND RUBBER CO. Email | Print | Comments (0) No. ERISA abounds with the language and terminology of trust law. [489 . . Restatement (Second) of Trusts § 187, Comment d (1959), Respondents unsuccessfully sought plan information from Firestone pursuant to 29 U.S.C. 93-533, p. 11 (1973). A trustee may be given power to construe disputed or doubtful terms, and in such circumstances the trustee's interpretation will not be disturbed if reasonable. Â. Argued November 30, 1988 Decided February 21, 1989 CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT *104 Martin Wald argued the cause for petitioners. 40. If the plan did not give the employer or administrator discretionary or final authority to construe uncertain terms, the court reviewed the employee's claim as it would have any other contract claim - See H. R. 6226, 97th Cong., 2d Sess. See Restatement (Second) of Trusts 187 (1959) ("Where discretion is conferred upon the trustee with respect to the exercise of a power, its exercise is not subject to control by the court except to prevent an abuse by the trustee of his discretion"). There is an obvious parallelism here: one "may become" eligible by acquiring, in the future, the same characteristic of eligibility that someone who "is" eligible now possesses. It reasoned that, in such situations, deference is unwarranted, given the lack of assurance of impartiality on, the part of the employer. De novo review is the appropriate standard for reviewing Firestone's denial of benefits to respondents. It noted, however, that the arbitrary and capricious standard had been softened in cases where fiduciaries and administrators had some bias or adverse interest. Sandra Day O’Connor: The first of these cases is Firestone Tire & Rubber Company versus Bruch, No. ed. No. Firestone and its amici also assert that a de novo standard would contravene the spirit of ERISA because it would impose much higher administrative and litigation costs and therefore discourage employers from creating benefit plans. U.S. 101, 107] See 29 CFR 2520.104b-30(b) (1987) (the "charge assessed by the plan administrator to cover the costs of furnishing documents is reasonable if it is equal to the actual cost per page to the plan for the least expensive means of acceptable reproduction, but in no event may such charge exceed 25 cents per page"). "This view attributes conventional meanings to the statutory language since all employees in covered employment and former employees with a colorable claim to vested benefits `may become eligible.' Nachman Corp. v. Pension Benefit Guaranty Corp. The raison d'etre for the LMRA standard -- the need for a jurisdictional basis in benefits denial suits against joint labor-management pension plan trustees whose decisions are not expressly made reviewable by the LMRA -- is not present in ERISA, which explicitly authorizes suits against fiduciaries and plan administrators to remedy statutory violations, including breaches of fiduciary duty and lack of compliance with plans. Congress did not say that all "claimants" could receive information about benefit plans. Trust principles make a deferential standard of review appropriate when a trustee exercises discretionary powers. With respect to Count VII, the District Court held that, although § 1024(b)(4) imposes a duty on a plan administrator to respond to written requests for information about the plan, that duty extends only to requests by plan participants and beneficiaries. From these provisions, Firestone concludes that an ERISA plan administrator, fiduciary, or trustee is empowered to exercise all his authority in a discretionary manner subject only to review for arbitrariness and capriciousness. Justice O’Connor, For the Court. In Firestone Tire, the Court reasoned that the default standard of review for ERISA benefits cases should be de novo; but, because plan administrators Id., at 138-140. U.S. 359, 446 U. S. 361 (1980), ERISA does not set out the appropriate standard of review for actions under § 1132(a)(1)(B) challenging benefit eligibility determinations. 1024(b)(4) without paying the $100-a-day damages assessable for breach of that obligation, 29 U.S.C. We do not think Congress' purpose in enacting the ERISA disclosure provisions - ensuring that "the individual participant knows exactly where he stands with respect to the plan," H. R. Rep. No. be subject to judicial review, the assumption seems to be that a de novo standard would encourage more litigation by employees, participants, and beneficiaries who wish to assert their right to benefits. U.S. 101, 116] Firefox, or This case presents two questions concerning the Employee Retirement Income Security Act of 1974 (ERISA), 88 Stat. Audio Transcription for Opinion Announcement – February 21, 1989 in Firestone Tire & Rubber Company v. Bruch William H. Rehnquist: The opinions of the Court in three cases will be announced by Justice O’Connor. 640 F. Supp. Without this jurisdictional analogy, LMRA principles offer no support for the adoption of the arbitrary and capricious standard insofar as 1132(a)(1)(B) is concerned. That provision reads as follows: "The administrator shall, upon written request of any participant or beneficiary, furnish a copy of the latest updated summary plan description, plan description, and the latest annual report, any terminal report, the bargaining agreement, trust agreement, contract, or other instruments under which the plan is established or operated. No. Woven industrial fabrics, from polyester and polyamide. 489 U. S. 108-115.   Petitioner Firestone Tire & Rubber Co. (Firestone) maintained, and was the plan administrator and fiduciary of, a termination pay plan and two other unfunded employee benefit plans governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. Water based adhesives for polyester fabrics treatment. Firestone set forth four principles of … V. BRUCH ET AL. Rather, that definition of a "participant" as "any employee or former employee . With respect to Count VII, the Court of Appeals held that the right to request and receive information about an employee benefit plan, "most sensibly extend[s] both to people who are in fact entitled to a benefit under the plan and to those who claim to be, but in fact are not.". Adopting Firestone's . Moreover, ERISA provisions that define a fiduciary as one who "exercises any discretionary authority," give him control over the plan's operation and administration, and require that he provide a "full and fair review" of claim denials cannot be interpreted to empower him to exercise all his authority in a discretionary manner. Complaint § 9, App. The Court of Appeals also held that the right to disclosure of plan information extends both to people who are entitled to plan benefits and to those who claim to be, but are not, so entitled. 828 F.2d, at 137-145. At the time of the sale of its Plastics Division, Firestone was not aware that the termination pay plan was governed by ERISA, and therefore had not set up a claims procedure, 1133, nor complied with ERISA's reporting and disclosure obligations, 1021-1031, with respect to that plan. First, we address the appropriate standard of judicial review of benefit determinations by fiduciaries or plan administrators under ERISA. § 1024(b)(4), one of. Because even under the arbitrary and capricious standard, an employer's denial of benefits could. Without more, we cannot ascribe to Congress any acquiescence in the arbitrary and capricious standard. See 29 CFR § 2520.104b-30(b) (1987) (the "charge assessed by the plan administrator to cover the costs of furnishing documents is reasonable if it is equal to the actual cost per page to the plan for the least expensive means of acceptable reproduction, but in no event may such charge exceed 25 cents per page"). A "participant" entitled to disclosure under § 1024(b)(4) and to damages for failure to disclose under § 1132(c)(1)(B) does not include a person who merely claims to be, but is not, entitled to a plan benefit. We granted certiorari, All three of the plans were either "employee welfare benefit plans" or "employee pension benefit plans" governed (albeit in different ways) by ERISA. 87-1054. by Phillip E. Stano, Jack H. Blaine, and David J. Larkin, Jr.; for the Chamber of Commerce of the United States et al. Just as trust beneficiaries could sue breaching trustees, so can petitioners. This view attributes conventional meanings to the statutory language, since the "may become eligible" phrase clearly encompasses all employees in covered employment and former employees with a colorable claim to vested benefits, but simply does not apply to a former employee who has neither a reasonable expectation of returning to covered employment nor a colorable claim to vested benefits. As they do with contractual provisions, courts construe terms in trust agreements without deferring to either party's interpretation. Lower court United States Court of Appeals for the Third Circuit . And I find it contrary to normal usage to think that the characteristic of "being" eligible consists of "having prevailed in a suit for benefits."   In light of Congress' general intent to incorporate much of LMRA fiduciary law into ERISA, see NLRB v. Amax Coal Co., I join the judgment of the Court and Parts I and II of its opinion. Of course, if a benefit plan gives discretion to an administrator or fiduciary who is operating under a conflict of interest, that conflict must be weighed as a "facto[r] in determining whether there is an abuse of discretion." A comparison of the LMRA and ERISA, however, shows that the wholesale importation of the arbitrary and capricious standard into ERISA is unwarranted. (A) for the relief provided for in [§ 1132(c)], [and] (B) to recover benefits due to him under the terms of his plan.". 828 F.2d at 152. . a plan participant is, "any employee or former employee . Despite these principles of trust law pointing to a de novo standard of review fOr claims like respondents', Firestone would have us read ERISA to require the application of the arbitrary and capricious standard to such claims. ERISA defines a fiduciary as one who "exercises any discretionary authority or discretionary control respecting management of [a] plan or exercises any authority or control respecting management or disposition of its assets." A comparison of the LMRA and ERISA, however, shows that the wholesale importation of the arbitrary and capricious standard into ERISA is unwarranted. Argued November 30, 1988. Faced with the possibility of $100 a day in penalties under 1132(c)(1)(B), a rational plan administrator or fiduciary would likely opt to provide a claimant with the information requested if there is any doubt as to whether the claimant is a "participant," especially when the reasonable costs of producing the information can be recovered. Firestone was the sole source of funding for the plans, and had not established separate trust funds out of which to pay the benefits from the plans. The discussion which follows is limited to the appropriate standard of review in 1132(a)(1)(B) actions challenging denials of benefits based on plan interpretations. United Mine Workers of America Health and Retirement Funds v. Robinson, 455 U. S. 562, 455 U. S. 573-574 (1982) (common law of trusts did not alter nondiscretionary obligation of trustees to enforce eligibility requirements as required by LMRA trust agreement). Search for: "Firestone Tire & Rubber Co. v. Bruch" Results 1 - 20 of 30. I agree with its disposition, but not all of its reasoning, regarding Part III. who is or may become eligible" for benefits must be naturally read to mean either an employee in, or reasonably expected to be in, currently covered employment, or a former employee who has a reasonable expectation of returning to covered employment or a colorable claim to vested benefits. Materials and industrial products exercise of a power is permissive or mandatory depends upon the terms of and! 412 U. S. 56 ; Reply Brief for American Council of Life Insurance et al search use! § 560, pp the preceding sentence requests for information concerning benefits under the termination plan... Two questions concerning the employee Retirement Income Security Act of 1974 ( ERISA ). Dedeaux... 2D Sess v. Eaton, 91 U. S. 56 trustee exercises discretionary powers -. Act 's fiduciary responsibility provisions, courts construe terms in trust agreements without deferring to either party 's.. 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Given Deference in Lawsuits challenging plan terms stay up-to-date with FindLaw 's for! 4Th ed.1988 ).: Economic Activity * Court vote: 9–0: any... ( f )., respondents admitted at oral argument that `` the exercise a... ( 1987 ) ( b ) ( describing scope of 1132 ( a ) ( i ). n.! States as amicus curiae 14-15, n. 40 ( 1986 ). to. J. Wright Argued the cause for the United States, which provides that, any... They may also leave gaps Retrieved from the Court in Adcock v. the Firestone Tire and Rubber Co. v.,... Concerning benefits under the preceding sentence | Print | Comments ( 0 ) no panoply of remedial ''... ( 1986 ). Petitioner Firestone Tire & Rubber Company v. Bruch Syllabus Tire! Amended, 29 U.S.C the intent of an earlier one. the United States v. Detroit Lumber Co. 460... Wright Argued the cause for the THIRD CIRCUIT no, one is a `` comprehensive and reticulated,. 1289 - United STEELWORKERS of AM requests for information, respondents admitted at oral that! Pp.193-208 ( 2d 560, pp.193-208 ( 2d with contractual provisions, courts construe in! Https: //www.loc.gov/item/usrep489101/ producing the information under § 1002 ( 7 )., Firestone denied the requests for,... Earlier one. and Rubber Co. v. Bruch, 489 U. S. 724-725 ( 1875 ) ( 1 (... Lmra ). intent of an earlier one. upon the terms of use privacy... `` may become eligible '' has nothing to do with the judicial interpretation of the in. Of credited Company service. `` Department of Labor ] may by regulation prescribe the maximum which... `` have heavily by Firestone do not think that this bit of legislative inaction carries the Day Firestone... Respect to the Court of Appeals for the THIRD CIRCUIT no mla citation style: o'connor, D.. Could sue breaching trustees, so can petitioners reasonable charge to cover the cost of furnishing such complete.. Also sought information 105 ; see firestone tire and rubber co v bruch Comment, the arbitrary and capricious standard trust beneficiaries could breaching!, and remand the case for further proceedings we likewise express no views as to the appropriate standard for Firestone... Of law, Firestone itself was the administrator may make a deferential standard of review is the appropriate of! U.S. 101 ( 1989 ) no Email | Print | Comments ( 0 no... S. 391, 399 ( 1973 ) -- will be thwarted by a natural reading the! Which persons are `` participants '' under § 1002 ( 7 )., 1132 ( a ), otherwise., 71 Cornell L.Rev the requests for information, respondents sought damages under 29 U.S.C create attorney-client. Written language ” to decide what an agreement means gap, federal courts have adopted the arbitrary and Test... Co. Email | Print | Comments ( 0 ) no administrator may make a deferential of. Receive information about benefit plans covered by ERISA firestone tire and rubber co v bruch governed by principles of contract law in. Legislative inaction carries the Day for Firestone § 560, pp producing the information because they were no longer participants... D. Crawford, Deena Jo Schneider, Steve D. Shadowen, and Bruce R. Lerner ( the one at here! Analyze case law published on our site to do with contractual provisions, 29 U.S.C on... Him on the Brief were Laurence Gold, Paula R. Markowitz, and Parts i and VII could... Earlier one. and industrial products 1 ), reprinted in Pension Legislation: Hearings on.... Dedeaux, 481 U.S. 41, 52 -57 ( 1987 ) ( 1 ) i... Under the arbitrary and capricious standard the maximum amount which will constitute a reasonable charge to the..., so can petitioners appropriate standard of judicial review of fiduciary Claim Denials under a... Longer `` participants '' in the judgment of the Labor Management Relations Act, 1947 LMRA! F.2D 134, affirmed in part and concurring in the judgment, post, p. 11 1973... Or otherwise, does not provide for judicial review of benefit plans covered by ERISA [ a... G., Brief for United States Court of Appeals reversed the District Court 's grant of summary judgment Counts! Fratcher, Scott on Trusts 187, p. 489 U. S. 148 of! Annotations is a forum for attorneys to summarize, Comment on, and Thomas M. Forman '' in the...., as amended, 29 U.S.C [ 489 U.S. 101, 116 ]  's. 20 of 30 24-25 ; Reply Brief for petitioners 7, n. 11 deferring to either party 's.. That respondents were `` participants '' with respect to the benefit plans about which sought., e.g., Brief for American Council of Life Insurance et al benefit! Under § 1002 ( 21 ) ( 1982 ed., Supp 1024 ( b ) ( ). More, we address the appropriate standard of judicial review of the term ``.. Which provides that a `` participant. v. Merck & Co., 616 F. Supp: 30! 481 U. S. 399 ( 1973 ). cause for the United States of!

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