McCutcheon v. Colgate-Palmolive Co., No. 20-3225, __F.4th__, 2023 WL 2467367 (2d Cir. Mar. 13, 2023) (Livingston, Sack, Circuit Judges, and Cogan, District Judge (EDNY)).
Plaintiff-Appellee Rebecca McCutcheon was a participant in the Colgate-Palmolive Co.’s Employees’ Retirement Income Plan (the “Plan”), a defined-benefit pension plan, that was converted from a final-average-pay plan to a cash-balance plan in 1989. After her retirement, the Plan was amended retroactively with respect to paying and calculating accrued benefits through payment of residual annuities. McCutcheon brought a putative class action under ERISA against the plan sponsor, plan administrator, and related defendants, alleging that the plan sponsor wrongly calculated, and underpaid, accrued retirement benefits in the form of residual annuities for participants who took their benefits as a lump sum rather than as an annuity.
The district court granted summary judgment to Defendants on several counts but granted summary judgment to the Plaintiff Class on a subset of its claims. Colgate appealed the order and final judgment of the district court. The Second Circuit Court of Appeals concluded that the Plaintiffs-Appellees interpretation of the Plan is the unambiguously correct reading of the Plan’s text. The Second Circuit made the following holdings as summarized by Thomson Reuters:
*Please note that this blog is a summary of a reported legal decision and does not constitute legal advice. This blog has not been updated to note any subsequent change in status, including whether a decision is reconsidered or vacated. The case above was handled by other law firms, but if you have questions about how the developing law impacts your ERISA benefit claim, the attorneys at Roberts Disability Law, P.C. may be able to advise you so please contact us.
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