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Kessler v. ADT Security Services, Inc.

Citation: 33 F. App'x 850Docket: No. 01-15594; D.C. No. CV-99-00814-LDG

Court: Court of Appeals for the Ninth Circuit; February 25, 2002; Federal Appellate Court

Narrative Opinion Summary

The case involves a plaintiff seeking early retirement benefits under an ERISA-regulated pension plan managed by the defendant. The primary legal issue centers on whether the plaintiff met the requisite ten years of continuous service to qualify for these benefits. The district court evaluated the plaintiff's service in two parts: under a 1985 plan, where he accrued minimal service due to insufficient working hours, and under a 1989 plan, where he accumulated additional years of service. Combined, these periods amounted to approximately nine years and nine months, falling short of the required ten years. Additionally, the plaintiff's invocation of equitable estoppel was dismissed, as the plan benefits were dispensed from a trust fund, making such a claim inapplicable as it would contravene the plan's explicit terms. The court upheld the denial of the benefits, affirming the lower court's judgment, and noted that the decision is not for publication or citation except under specific rules of the Ninth Circuit.

Legal Issues Addressed

Calculation of Continuous Service Under ERISA Plans

Application: The court calculated the plaintiff's continuous service by assessing employment periods under two different versions of the pension plan to determine eligibility for early retirement benefits.

Reasoning: The district court's calculation of Kessler's service is conducted in three stages: service prior to January 1, 1989, under the 1985 Plan; service after January 1, 1989, under the 1989 Plan; and the total of both periods.

Eligibility for Early Retirement Benefits

Application: The plaintiff did not meet the ten-year continuous service requirement necessary for early retirement benefits under the ERISA-regulated pension plan.

Reasoning: This results in a total of approximately nine years and nine months of service, falling short by three months for eligibility for early retirement benefits.

Equitable Estoppel in ERISA-Regulated Plans

Application: The court rejected the plaintiff's claim of equitable estoppel because the pension benefits were paid from a trust fund, and such claims are barred when they contradict the written terms of an ERISA plan.

Reasoning: Kessler's attempt to invoke equitable estoppel is also unsuccessful because it is barred by precedent where ERISA plans involve trust funds, and recovery would contradict the written terms of the plan.