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Parson v. Union Underwear Co.
Citation: 95 F. App'x 144Docket: No. 02-5711
Court: Court of Appeals for the Sixth Circuit; April 12, 2004; Federal Appellate Court
Wayne Parson and Charley Huckaby, former employees of the Union Underwear plant in Campbellsville, Kentucky, sought disability retirement benefits under the company’s pension plan after the plant closed in 1999. Both were on approved medical leave at the time of the closure. Their applications for benefits were denied, prompting them to file a lawsuit under ERISA (29 U.S.C. 1001 et seq.) to compel payment. The district court dismissed Parson’s claim for failure to exhaust administrative remedies but upheld the denial of Huckaby’s claim. On appeal, the court reversed the dismissal of Parson’s claim, determining that the district court abused its discretion. Parson had not submitted his claims directly to the pension plan committee but had stipulated he requested benefits and that those requests were denied and confirmed. The appellate court concluded that these stipulations waived the exhaustion requirement, as they bound both parties and the court, and indicated that resubmitting his claim would be futile. Regarding Huckaby, he contested the application of the "arbitrary and capricious" standard of review to the pension committee's denial of his benefits. The appellate court reviewed the appropriate standard of review de novo, noting that the plan granted discretionary authority to the committee. Huckaby argued that the committee's delay in responding warranted de novo review; however, the court found it unnecessary to resolve this since Huckaby did not meet the plan’s criteria for benefits under either standard. Huckaby does not meet the criteria for disability retirement benefits under Union Underwear’s pension plan, as determined by the court's de novo review of the district court's decision. While Huckaby satisfies two of the four criteria (age and length of service), he fails to meet the other two: 1) severance of service due to a disability, as defined by the plan, and 2) eligibility for Social Security Administration (SSA) disability benefits during approved medical leave or while receiving long-term disability benefits. The plan defines "disabled" as a condition where a physician selected by the Committee determines the employee cannot engage in any employment due to a permanent and continuous bodily injury or disease. Although the SSA found Huckaby disabled prior to the closure of the Campbellsville plant, this determination does not equate to meeting the pension plan’s definition of disability. Union Underwear's materials explicitly state that SSA disability is only one requirement for plan benefits. Since the pension plan committee did not find Huckaby disabled at the time of the plant's closure, he does not meet the plan's criteria, negating the need to consider the remaining requirement regarding SSA benefits. Consequently, the court reverses the district court's dismissal of Parson's similar claim and remands for judgment in favor of the defendants, while affirming the judgment denying Huckaby's claim for disability retirement benefits.