FIRESTONE TIRE & RUBBER CO. – Appellant
Versus
BRUCH, (1989) – Respondent
FIRESTONE TIRE & RUBBER CO. v. BRUCH, (1989)
No. 87-1054
Argued: November 30, 1988 Decided: February 21, 1989
Petitioner Firestone Tire & Rubber Co. (Firestone) maintained, and was the plan administrator and fiduciary of, a termination pay plan and two other unfunded employee benefit plans governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. After Firestone sold its Plastics Division to Occidental Petroleum Co. (Occidental), respondents, Plastics Division employees who were rehired by Occidental, sought severance benefits under the termination pay plan, but Firestone denied their requests on the ground that there had not been a "reduction in work force" that would authorize benefits under the plans terms. Several respondents also sought information about their benefits under all three plans pursuant to 1024(b)(4)s disclosure requirements, but Firestone denied those requests on the ground that respondents were no longer plan "participants" entitled to information under ERISA. Respondents then brought suit for severance benefits under 1132(a)(1)(B) and for damages under 1132(a)(1)(A) and (c)(1)(B) based on Firestones breach of its statutory disclosure obligation. The Federal District Court granted summary judgment for Firestone, holding that the company had satisfied its fiduciary duty as to the benefits requests because its decision not to pay was not arbitrary or capricious, and that it had no disclosure obligation to respondents because they were not plan "participants" within the meaning of 1002(7) at the time they requested the information. The Court of Appeals reversed and remanded, holding that benefits denials should be subject to de novo judicial review rather than review under the arbitrary and capricious standard where the employer is itself the administrator and fiduciary of an unfunded plan, since deference is unwarranted in that situation given the lack of assurance of impartiality on the employers part. The Court of Appeals also held that the right to disclosure of plan information extends both to people who are entitled to plan benefits and to those who claim to be, but are not, so entitled.
Held:
- 1. De novo review is the appropriate standard for reviewing Firestones denial of benefits to respondents. Pp. 108-115. [489 U.S. 101, 102]
- (a) The arbitrary and capricious standard - which was developed under the Labor Management Relations Act, 1947 (LMRA) and adopted by some federal courts for 1132(a)(1)(B) actions in light of ERISAs failure to provide an appropriate standard of review for that section - should not be imported into ERISA on a wholesale basis. The raison detre for the LMRA standard - the need for a jurisdictional basis in benefits denial suits against joint labor-management pension plan trustees whose decisions are not expressly made reviewable by the LMRA - is not present in ERISA, which explicitly authorizes suits against fiduciaries and plan administrators to remedy statutory violations, including breaches of fiduciary duty and lack of compliance with plans. Without this jurisdictional analogy, LMRA principles offer no support for the adoption of the arbitrary and capricious standard insofar as 1132 (a)(1)(B) is concerned. Pp. 108-110.
- (b) Principles of the law of trusts - which must guide the present determination under ERISAs language and legislative history and this Courts decisions interpreting the statute - establish that a denial of benefits challenged under 1132(a)(1)(B) must be reviewed under a de novo standard unless the benefit plan expressly gives the plan administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the plans terms, in which cases a deferential standard of review is appropriate. The latter exception cannot aid Firestone, since there is no evidence that under the termination pay plan the administrator has the power to construe uncertain plan