Employees No Longer Under Controlled Group Entitled to Enhanced Benefits

By Rebecca Moore | March 15, 2017
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The district court adopted the 6th U.S. Circuit Court of Appeals reasoning in Adams v. Anheuser-Busch Cos., which the 8th Circuit said presented “the identical issue.” The district court concluded the plan administrator’s denial of benefits was “arbitrary and capricious. Three months after the district court entered judgment on the pleadings, the district court granted Anheuser-Busch’s motion for a final order and stay of judgment pending appeal. Rejecting plaintiffs’ request to calculate the specific amount of benefits due to each class member, the district court simply ordered Anheuser-Busch to direct the plan administrator to provide each member of the class with the enhanced pension benefit under Section 19.11(f).

Citing 8th Circuit Local Rule 47A, plaintiffs moved to dismiss Anheuser-Busch’s appeal on the basis that the district court had not yet issued a final order. Plaintiffs argue another 8th Circuit decision in Dieser v. Continental Casualty Co. “confirms” the district court’s order entering judgment was not final because it failed to calculate the benefits owed to each member of the class. Although plaintiffs contend the order is not final because they were not awarded damages, the district court considered their argument but decided the nature of their action was declaratory, and they were not entitled to an award that calculated the benefits owed.

Upon examination of plaintiffs’ prayer for relief in Count I of their consolidated complaint, the appellate court concluded that plaintiffs made a sufficient request for an actual award of certain benefits with the application of the enhanced benefit—in addition to a declaration that Section 19.11(f) applies. Therefore, the appellate court reversed and remanded the case back to the district court with instructions to reconsider the plaintiffs’ prayer for relief and, to the extent requested and provable, calculate and award the benefits owed to plaintiffs by applying Section 19.11(f). Upon remand, the district court may reconsider whether certain records will assist in its calculation of the requested benefits, the 8th Circuit said.

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