Third Circuit Unanimously Affirms Lower Court’s Rejection of ERISA Claims Against SRZ Client

The Third Circuit ruled in favor of SRZ client Amalgamated Life Insurance Co. on Sept. 16, 2013, affirming a district court decision that found Amalgamated had not violated the Employee Retirement Income Security Act (ERISA) by not providing pensions to 12 former employees. The plaintiffs, unionized workers at a Pennsylvania service center employed by Amalgamated as part of an outsourcing arrangement with the Union Labor Life Insurance Company, alleged that Amalgamated violated ERISA both by interfering with their right to pension benefits and misrepresenting their entitlement to those benefits. The U.S. District Court for the Eastern District of Pennsylvania granted summary judgment to Amalgamated in October 2012 and dismissed the case, Jenkins et al. v. Union Labor Life Insurance Company Inc. et al., finding the plaintiffs failed to prove interference with ERISA rights. The plaintiffs appealed to the Third Circuit only with respect to the plaintiff’s equitable estoppel claim. In its unanimous ruling, the Third Circuit not only affirmed the district court’s decision but expanded upon it by determining that the plaintiffs’ reliance on language in a question-and-answer document and a separate general overview of benefits that they received in connection with the outsourcing, if there was any, was not reasonable.

The SRZ team representing Amalgamated in this case included employment & employee benefits partner Ronald E. Richman and special counsel Scott A. Gold.