U.S. Court of Appeals for the Third Circuit

PHILADELPHIA – The U.S. Court of Appeals for the Third Circuit upheld a ruling from the U.S. District Court for the Eastern District of Pennsylvania which denied pension benefits to a deceased man’s son, who is currently incarcerated in Collegeville.

In a per curiam opinion issued Feb. 11, Judges Thomas L. Ambro, Patty Shwartz and Morton I. Greenberg decided to affirm the trial court ruling which declared Thomas E. Robinson Jr. was not eligible to receive the pension benefits afforded to his late father, Thomas E. Robinson Sr.

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 defendant William James Derrah Sr., 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., which 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 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.

Summarily, Robinson Jr. filed suit to recover his father’s pension in January 2014, to which Laneko and Derrah moved for summary judgment. The defendants argued “(1) Robinson Jr. lacked standing to pursue an action for the recovery of his father’s alleged pension benefits, (2) the claim for benefits was barred by the statute of limitations, and (3) Robinson Jr. failed to establish that any benefits due to his father had not already been paid.”

The District Court agreed with the defendants that the case was governed by the Employee Retirement Income Security Act (ERISA), and that Robinson Jr. lacked relevant ERISA standing in this matter to receive his father’s benefits, in a July 1 ruling. Robinson Jr. timely appealed to the Third Circuit.

“Section 502(a) of ERISA empowers ‘a participant or beneficiary’ to bring a civil action ‘to recover benefits due to him under the terms of his plan,” the Third Circuit said. “A ‘participant’ is any employee or former employee of an employer 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 whose beneficiaries may be eligible to receive any such benefit.”

The Third Circuit said it was “undisputed” in this case that Robinson Jr. was not a “participant” under his father’s pension plan at Laneko, nor had he produced evidence to show he was a beneficiary under this same plan.

“Accordingly, we agree with the District Court that he lacks standing to pursue a claim for the recovery of his father’s pension benefits. Although Robinson Jr. contends that (1) his mother is entitled to his father’s pension benefits, and (2) she has given him (Robinson Jr.) permission to pursue those benefits on her behalf, the District Court correctly concluded that he could not sue on his mother’s behalf,” the Third Circuit said.

The Third Circuit opted to uphold the ruling of the District Court and deny Robinson Jr. access to his father’s Laneko pension plan benefits.

“In light of the above, we agree with the District Court’s decision to grant the defendants’ motion for summary judgment,” the Third Circuit concluded.

The defendants are represented by James J. Rodgers of Dilworth Paxson, in Philadelphia.

U.S. Court of Appeals for the Third Circuit case 15-2837

U.S. District Court for the Eastern District of Pennsylvania case 2:14-cv-05036

From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at nickpennrecord@gmail.com

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