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Eckardt v. Wiebel Tool Co.

Citations: 965 F. Supp. 357; 1997 U.S. Dist. LEXIS 7498; 1997 WL 282454Docket: No. 94 CV 4374 (ADS)

Court: District Court, E.D. New York; May 27, 1997; Federal District Court

Narrative Opinion Summary

In this case, former employees of Wiebel Tool Company, Inc. brought claims under the Employee Retirement Income Security Act (ERISA) against multiple defendants, including the company’s current and former owners, as well as Equitable Life Assurance Society. The plaintiffs alleged breach of fiduciary duty and failure to provide information under ERISA, in addition to a state law claim for intentional infliction of emotional distress. They contended that a deferred compensation plan constituted an ERISA-regulated plan, which the court rejected, finding no ongoing administrative scheme or managerial discretion necessary for ERISA applicability. Additionally, the court determined the plaintiffs' ERISA claims were time-barred, as they were filed beyond the statute of limitations. Three motions for summary judgment were considered, and the court granted them in favor of the defendants, dismissing the case for lack of subject matter jurisdiction. Furthermore, the court allowed the withdrawal of counsel for one defendant due to non-payment of fees. The court's decision effectively dismissed all claims against the defendants and closed the case.

Legal Issues Addressed

ERISA Qualification of Employee Benefit Plans

Application: The court evaluated whether the 1981 Agreement and 1985 Modification qualified as an ERISA plan, concluding they did not due to the lack of an ongoing administrative scheme and managerial discretion.

Reasoning: Plaintiffs argue there exists an adequate administrative scheme to support their ERISA claims, but the Court disagrees. They assert that the benefits are clearly defined in the 1981 Agreement and 1985 Modification, which outline that benefits will be calculated based on the cash surrender value of the life insurance policy.

Statute of Limitations for ERISA Claims

Application: The court determined that the plaintiffs' ERISA claims for breach of fiduciary duty were time-barred as they were filed after the statute of limitations had expired.

Reasoning: The court addressed the defendants' statute of limitations argument regarding the plaintiffs' claims under ERISA for breaches of fiduciary duties... Since the plaintiffs did not bring their action until September 16, 1994, their claims were deemed time-barred.

Summary Judgment Standards

Application: The court applied the standard for summary judgment, requiring no genuine issues of material fact for the movant to succeed, and found in favor of the defendants on this basis.

Reasoning: The standard for summary judgment dictates that it may be granted if no genuine issue of material fact exists when evidence is viewed favorably to the opposing party, and the movant is entitled to judgment as a matter of law.

Withdrawal of Counsel

Application: The court permitted the withdrawal of Lawrence Brochin, Esq. as counsel for Jack Mangesian due to non-payment of legal fees, which was unopposed by both parties.

Reasoning: Additionally, Lawrence Brochin, Esq. sought to withdraw as counsel for defendant Jack Mangesian due to Mangesian's failure to pay legal fees, a motion which both Mangesian and the plaintiffs did not oppose.