PHILADELPHIA – A Collegeville prisoner’s attempt to secure pension benefits on behalf of his deceased father was rejected in federal court on Wednesday.
Judge Gerald J. Pappert of the U.S. District Court for the Eastern District of Pennsylvania dismissed claims brought by Thomas E. Robinson, Jr., an inmate at Graterford Correctional Facility in Collegeville, against Laneko Engineering Company of Fort Washington and William James Derrah, Sr. of Avalon, N.J., the company’s principal stockholder.
The plaintiff’s father, Thomas E. Robinson, Sr., began working at Laneko Engineering Company on April 22, 1974, and began participating in the company’s pension plan a year later – a plan overseen and administrated by Derrah, according to court records.
Laneko terminated its pension plan on Nov. 16, 1998. About two months before the termination, Laneko sent a letter to Robinson Sr., that indicated he had an accrued benefit of $332.50 per month, payable as a life annuity once he reached the age of 65. The lump sum value of the annuity benefit was $18,889.36.
The letter explained that Robinson Sr. had four options. He could: Transfer the lump sum value into the Laneko 401(k) plan; transfer the lump sum value into an IRA; receive a distribution of the lump sum value, subject to tax withholding; or receive the monthly annuity to commence when he reached age 65. The parties dispute what option, if any, Robinson Sr. chose.
Robinson Jr. produced an election form with option four (the annuity) selected and dated May 5, 1999, but it is unsigned. According to court records, the defendants are uncertain as to whether they ever received an election form from Robinson Sr., but they contend the insurance company that purchased the annuity contracts has no record of purchasing one in Robinson Sr.’s name.
Robinson Sr. died on Dec. 23, 2007, at the age of 61. Robinson Jr. alleges before his father’s death, Robinson Sr. never received any pension benefits, as a rollover, a lump sum distribution, or an annuity.
On Jan. 13, 2014, Robinson Jr. filed a complaint in the Montgomery County Court of Common Pleas to recover his father’s pension. Though lacking any specific counts, it appeared to allege state law claims for breach of contract and conversion.
The complaint does not contain any specified “counts,” but appears to allege state law claims for breach of contract and conversion. The defendants removed the action to federal court, arguing that Robinson Jr.’s claims are subject to the Employee Retirement Income Security Act (ERISA), which provided the Court with federal jurisdiction in this matter. Subsequent to a discovery process, the defendants moved for summary judgment on March 2.
The defendants put forth three arguments to support their summary judgment motion: That Robinson Jr. had not produced sufficient evidence asserting his father did not receive his pension benefits prior to his death; that Robinson Jr’s claims were barred by relevant statutes of limitations; and that Robinson Jr. did not possess proper standing under ERISA to pursue his claims.
Pappert explained though there appeared to be no federal claim on the face of the complaint, seeking pension benefits for a plan falling under the auspices of ERISA made the dispute a federal matter and termed the defendants’ removal of the action on that basis as “proper."
“ERISA’s civil enforcement provision specifies that ‘a participant or beneficiary’ may bring an action ‘to recover benefits due to him under the terms of his plan, to enforce his rights under the terms of the plan, or to clarify his rights to future benefits under the terms of the plan,” Pappert said.
“The statute defines a participant as ‘any employee or former employee of an employer, or any member or former member of an employee organization, who is or may become eligible to receive a benefit of any type from an employee benefit plan which covers employees of such employer or members of such organization, or whose beneficiaries may be eligible to receive any such benefit. It defines a beneficiary as a person designated by a participant, or by the terms of an employee benefit plan, who is or may become entitled to a benefit thereunder.”
Pappert stated an undisputed fact in the case was Robinson Sr. acting as the plan’s participant, which Robinson Jr.'s only possible role being to act as a beneficiary – an assertion Pappert found lacking in the lawsuit.
“Robinson Jr. has not presented any evidence to show that he is ‘a person designated by a participant, or by the terms of an employee benefit plan, who is or may become entitled to a benefit thereunder,” Pappert said. “He has not produced any beneficiary designation form, provided the relevant terms of the plan, or submitted an affidavit stating that he is a beneficiary as defined by ERISA. Because Robinson Jr. would bear the burden of establishing his standing at trial, this lack of evidence is conclusive at the summary judgment stage and fatal to Robinson Jr.’s claims.”
Though Robinson Jr. asserted his standing through a verified statement by his mother, Lydia Robinson, who gave her son permission to pursue the allegedly due benefits on behalf of his late father’s estate, Pappert found this statement insufficient to Robinson Jr.’s pursuit of the pension benefits.
“These arguments fail. Robinson Jr. is not an attorney. He therefore cannot sue in a representative capacity on his mother’s behalf – either individually or in her capacity as administrator of her late husband’s estate,” Pappert said. “Robinson Jr. cannot represent Ms. Robinson, and Ms. Robinson’s purported grant of authority for Robinson Jr. to ‘obtain my husband’s pension’ cannot confer ERISA standing on Robinson Jr.”
Pappert concluded by granting the defendants’ motion for summary judgment and dismissing Robinson Jr.’s claims.
“The Court concludes that Robinson Jr. lacks statutory standing to sue for pension benefits purportedly owed to his father. Consequently, the Court lacks subject matter jurisdiction over Robinson Jr.’s claims and therefore has no authority to rule on Defendant’s arguments that go to the merits of those claims. The complaint is dismissed for lack of subject matter jurisdiction,” Pappert said.
The plaintiff was seeking the release of his father’s pension benefits plus interest, punitive damages of $100,000 plus interest, consequential damages of $100,000 plus interest, attorney’s fees and court costs, plus any other relief allowable by law.
The plaintiff represented himself in this matter.
The defendants were represented by James J. Rodgers of Dilworth Paxson, in Philadelphia.
U.S. District Court for the Eastern District of Pennsylvania case 2:14-cv-06623
From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at firstname.lastname@example.org