Stanley A. Rodowicz v. Massachusetts Mutual Life Insurance Company, Stanley A. Rodowicz v. Massachusetts Mutual Life Insurance Company
Docket: 98-1654
Court: Court of Appeals for the First Circuit; November 2, 1999; Federal Appellate Court
The United States Court of Appeals for the First Circuit issued a memorandum and order concerning the case involving Stanley A. Rodowicz and others (plaintiffs/appellants) against Massachusetts Mutual Life Insurance Company and related entities (defendants/appellees). The court denied the defendants' petition for panel rehearing, rejecting their claims of a factual error regarding the timing of MassMutual's consideration of a workforce reduction. The court reaffirmed its previous findings, specifically noting that Senior Vice-President Susan Alfano's analysis of costs and benefits occurred between March and September 1992, consistent with the district court's assertions. The court also identified factual issues that preclude summary judgment concerning whether three plaintiffs could rely on statements from MassMutual personnel, clarifying that its current ruling is not definitive on these matters. Regarding the standard of review applied to the district court's determination that the termination program was not an Employee Retirement Income Security Act (ERISA) "plan," the panel decided to apply a de novo standard rather than clear error. However, this change did not affect the case's outcome, as the court concluded that the voluntary termination program in question was not an ERISA "plan." The court's decision was subject to modifications noted in an errata sheet, and the petition for rehearing was ultimately denied. Judge Aldrich, a participant in the original panel, did not take part in this order due to no longer serving as a judge on pending matters.