Tompkins v. Central Laborers’ Pension Fund

Federal 7th Circuit Court
Civil Court
Case Number: 
No. 12-1955
Decision Date: 
March 13, 2013
Federal District: 
C.D. Ill.
Dist. Ct. did not err in granting defendant-pension plan’s motion for summary judgment in ERISA action alleging that defendant wrongfully terminated plaintiff’s disability benefits based on its interpretation of “total and permanent disability” phrase in plan that, according to defendant, required termination of benefits whenever beneficiary obtained full-time employment. Plaintiff eventually became employed full-time in 2005 in 40 hour per week job and earned $10,550 that year and $22,100 in 2006. Although plan allowed plaintiff to earn up to $14,000 per calendar year and still be considered totally and permanently disabled, defendant did not act arbitrarily in finding that plaintiff was ineligible for benefits at time he began full-time employment in 2005 since plan’s definition of total and permanent disability was ambiguous, such that defendant could find that $14,000 provision applied only to beneficiaries employed on part-time basis. Ct. also rejected plaintiff’s claim that defendant breached fiduciary duty by failing to provide plaintiff with certain plan documents, where said documents did not pertain to disability benefits.