Narrative Opinion Summary
The case involves a dispute between a claimant and the San Francisco Culinary, Bartenders and Service Employees Pension Fund, Local 2, regarding the non-award of retroactive disability benefits. The district court ruled in favor of the Fund, concluding that the claimant forfeited his benefits. On appeal, the court affirmed the decision, conducting a de novo review of the summary judgment. The primary legal issue centered on whether the claimant's disability pension benefits were protected from forfeiture under 29 U.S.C. § 1054(g), which safeguards 'accrued benefits.' The court found that the claimant's benefits were 'qualified disability benefits' and not classified as 'accrued benefits' or a 'retirement-type subsidy.' Furthermore, the court held that the issue of notice regarding a 1997 plan amendment was immaterial since the claimant did not show active concealment or significant reliance on any lack of notice. Additionally, while the court denied the Fund's motion to strike the claimant's briefs for procedural non-compliance, it acknowledged the validity of some procedural objections. The appellate decision is not designated for publication and cannot be cited except as permitted by Ninth Circuit Rule 36-3.
Legal Issues Addressed
Definition of Qualified Disability Benefitsubscribe to see similar legal issues
Application: Barncord's benefits were classified as 'qualified disability benefits,' which are not considered 'accrued benefits' and are thus subject to forfeiture.
Reasoning: Barncord's disability pension was deemed a 'qualified disability benefit' and therefore not classified as an 'accrued benefit' or 'retirement-type subsidy.'
Procedural Compliance in Brief Filingssubscribe to see similar legal issues
Application: The court denied the motion to strike briefs for non-compliance but acknowledged the validity of some objections.
Reasoning: The court denied the Fund's motion to strike the briefs for procedural non-compliance but acknowledged that some objections raised by the Fund were valid.
Protection of Accrued Benefits under 29 U.S.C. § 1054(g)subscribe to see similar legal issues
Application: The court determined that Barncord's disability pension benefits were not protected from forfeiture as they were not considered 'accrued benefits' under the statute.
Reasoning: The court concluded that Barncord's disability pension benefits were not protected from forfeiture by the plan amendment under 29 U.S.C. § 1054(g), which only safeguards 'accrued benefits.'
Relevance of Notice in Plan Amendmentssubscribe to see similar legal issues
Application: The court found that notice of the 1997 amendment was irrelevant as Barncord failed to show concealment or reliance on a lack of notice.
Reasoning: Additionally, the issue of whether the Fund notified Barncord of a 1997 amendment was deemed irrelevant, as he did not demonstrate any active concealment or significant reliance on a lack of notice.