Court Dismisses Former Employee’s Contract and ERISA Claims as Unenforceable and Time-Barred

In Holmes v. Parker-Hannifin Corporation, No. 1:25-CV-01911, 2025 WL 3157610 (N.D. Ohio Nov. 12, 2025), the U.S. District Court for the Northern District of Ohio dismissed all claims brought by a former in-house attorney who alleged that Parker-Hannifin breached an oral agreement related to his resignation and interfered with his ERISA benefits. The court held that the plaintiff failed to plausibly allege the existence of any enforceable contract and that his ERISA claims were filed well outside the applicable statute of limitations.

Background

Plaintiff Holmes worked as an in-house attorney for Parker-Hannifin until 2019, when he resigned after discussions regarding his separation. The company presented him with a written separation agreement offering stock, vacation payout, and six weeks of severance pay, but the agreement was never executed. Holmes alleged that he agreed to resign based on Parker-Hannifin’s oral promise to negotiate a financial settlement in good faith—including a purported $16,000 severance payment—and to address issues related to 401(k) vesting.

Nearly three years after his resignation, Holmes contacted the company to raise concerns about the severance he believed he was owed. He then waited an additional three years before filing suit in 2025, asserting claims for breach of contract, failure to honor a deferral election under ERISA, and interference with ERISA benefits under Section 510.

Court’s Decision

No Enforceable Contract

The court dismissed the breach of contract claim, finding that Holmes alleged nothing more than an unenforceable “agreement to agree.” The written separation agreement was never signed, and the alleged oral promises lacked sufficiently definite terms to constitute a binding contract under Ohio law. Because Holmes failed to allege a valid contract, the claim could not proceed.

ERISA Claims Were Untimely

The court also dismissed Holmes’s ERISA claims—both his allegation that Parker-Hannifin failed to honor his deferral election and his claim of interference under ERISA § 510—as plainly time-barred. Holmes conceded that a three-year statute of limitations applied. Under ERISA, the limitations period begins when the plaintiff has “actual knowledge of the breach.” The court found that Holmes’s own allegations established that this occurred no later than August 2019, when he received his final pay and separation information.

The court emphasized that Holmes did not allege any facts suggesting he failed to review his final paycheck for more than three years, nor did he identify any later date on which he first learned of the alleged ERISA violations. The absence of any specific factual allegation regarding a delayed discovery date made his attempt to avoid the statute of limitations legally insufficient.

The court also highlighted Holmes’s July 18, 2022 email to Parker-Hannifin’s associate general counsel, in which he raised concerns about his severance and 401(k) benefits. This communication showed that Holmes unquestionably knew of the alleged issues no later than mid-2022. Even using that later date, the court noted, Holmes still waited another three years before filing suit in August 2025—double the limitations period.

Because both ERISA claims accrued no later than 2019—and certainly no later than 2022—the court concluded they were “clearly barred” by the statute of limitations. Importantly, the court declined to reach the question of whether Holmes had adequately alleged the required “specific intent” for a Section 510 interference claim or whether he had exhausted administrative remedies. The timeliness defect alone was dispositive.

Takeaway

This decision underscores the importance of timely action when disputing severance terms or benefit determinations under ERISA. The court emphasized that even for legally sophisticated plaintiffs—such as an attorney—claims must be supported by definite, enforceable contractual terms and must be filed within the applicable statute of limitations. Plaintiffs who believe their employer failed to honor severance commitments or interfered with retirement benefits should seek prompt legal guidance to preserve their rights.