Michelin Retirement Plan's Denial Of Disability Benefits Not Arbitrary
From June 1993 to February 1994, Pack experienced symptoms to such a degree that he was absent from work on several occasions. Pack did not return to work at all after February 9, 1994.
In September 1994, Pack's physician, Dr. Kenneth Hart, diagnosed Pack with multiple chemical sensitivity syndrome, possibly attributable to exposure to one or more unknown chemicals or substances at the tire facility. In Dr. Hart's opinion, Pack could return to work, but would have to avoid whatever unknown substances or odors may have created his symptoms. Because he failed to return to work, Pack was terminated from employment in May, 1995.
In April 1995, Pack applied for disability retirement benefits under the Michelin Retirement Plan. Pack was a qualified, vested participant in the Plan. The Plan was an employee pension plan authorized and governed by the requirements of ERISA. It was formed as a result of the merger of several pension plans maintained by Michelin, including the Uniroyal Goodrich Tire Company Tire Pension Plan. An entity referred to as the Pension and Benefits Appeals Board (the Board) was designated as the plan administrator for purposes of ERISA. The Plan gave the Board discretion to determine eligibility for benefits and to interpret the terms of the Plan.
The Plan provided for disability retirement benefits to any qualified participant "who, through no fault of his own, becomes totally and permanently disabled as a result of sickness or injury." The Plan's summary plan description defined permanent and total disability to mean that the participant is "no longer able to meet the requirements of his job and is not able to qualify for transfer to another job in the Ardmore Plant."
Pack's application for disability benefits was denied, and he appealed that decision to the Board. All of the Board members were given copies of the materials and information that Pack submitted. The Board met, discussed the information, and denied Pack's appeal on February 5, 1996 on the ground that the information Peck provided established that he could have performed the essential functions of his job as a tire builder.
Pack sued the Michelin Retirement Plan in the U.S. District Court For The Eastern District Of Oklahoma claiming the Board's denial of benefits was arbitrary and capricious.
The district court said that Peck did not have enough evidence to prove his case and dismissed Pack's claim without a trial. Pack appealed to the United States Court Of Appeals For The Tenth Circuit. After reviewing the evidence, the appeals court did not consider that Board's decision was unreasonable or taken in bad faith.
The appeals court said it was clear from Dr. Hart's report and the other evidence before the Board that Pack was currently in good health and able to work, but that further observation of Pack at work was needed. This was to ascertain what, if any, odors or substances at the tire facility were responsible for Pack's symptoms and whether Pack's symptoms reoccurred if he worked in different areas of the plant.
Pack never attempted to return to work, however, to see if he could avoid exposure to whatever substance or odor may have triggered his symptoms. Therefore, there was no evidence before the Board to support his claim that he could not return to work at the tire facility under any conditions.
Accordingly, the appeals court upheld the district court ruling.
Source: Pack v. Michelin Retirement Plan, 2000 U.S. App. LEXIS 23361mUnited States Court Of Appeals For The Tenth Circuit) (September 15, 2000)
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