Fifth Circuit Affirms Denial of ERISA Severance Plan Benefits Where Plan Administrator Found No Good Reason for Resignation Following Acquisition

In Gift v. Anadarko Petroleum Corporation Change of Control Severance Plan, et al., No. 23-50862, 2024 WL 4689051 (5th Cir. Nov. 6, 2024), the court considered whether Anadarko Petroleum Corporation’s Change of Control Severance Plan (“Plan”) abused its discretion in denying Plaintiff severance benefits based on his claim that he resigned for “good reason” following an acquisition. Plaintiff alleged that following Occidental Petroleum’s acquisition of Anadarko, he was assigned to the task of procedure writing and covering shifts in the Operations Control Center (“OCC”), which he believed he did not have the training and experience to do. The Plan pays benefits if there is “good reason” for resignation. The Plan provides that good reason includes if a “Participant is required, without the Participant’s prior written consent, to perform in a job position, or a substantial job assignment, for which he or she is not skilled or trained.” Plaintiff resigned and filed a claim for benefits. The Plan’s Committee denied his claim on the basis that his work in the OCC was voluntary. In response to arguments Plaintiff made on appeal, the Plan reasserted its original basis for denial and further concluded that Plaintiff did have the requisite knowledge and understanding of Operations to work in the OCC and no additional training was required.

 The court held that: (1) the district court properly applied abuse of discretion review because the Plan confers discretion on the plan administrator to construe the plan’s terms; (2) the Plan’s determination that Plaintiff did not have “good reason” to resign was reasonable, rejecting Plaintiff’s arguments that the Committee must make an individualized assessment when determining whether there is a need for skill and training, and the Plan’s guidance requires training for new job duties; and (3) the Plan’s additional reasoning for denial in the final appeal letter was not a “bait and switch,” rather it reiterated the basis for its determination and addressed Plaintiff’s arguments raised on appeal. Judgment affirmed.