Williams v. Rohm and Haas Pension Plan

Dist. Ct. did not err in approving proposed $180 million settlement of class action claim arising out of ERISA lawsuit alleging that defendant-pension plan failed to include cost of living adjustment to lump sum distributions to class members who elected to take early retirement. While record showed that all early retirees would receive recovery of at most only 35.5% of their requested relief, Dist. Ct. could properly approve of settlement where class claim rested on unsettled law. Moreover, Dist. Ct. could properly approve attorneys' fees totaling $43.5 million based on amount of work involved, risks of non-payment and quality of representation and find that pure percentage fee approach best replicated market for ERISA class action attorneys. Ct. rejected objector's contention that Dist. Ct.'s fee calculation was flawed because it did not give proper weight to lodestar crosscheck.