BIRMINGHAM, Ala. — Goodyear was awarded summary judgment recently in a case before the U.S. District Court for the Northern District of Alabama, Middle Division, regarding a Goodyear retiree's pension claims.
Loyd Watkins retired from Goodyear's Gadsden, Ala., tire factory in June 1991. At the time, he elected a pension option allowing for his surviving spouse to receive a pension upon his death.
Mr. Watkins' first wife died in 2014, and he remarried the next year. In January 2016, he wrote Goodyear asking that his second wife be allowed to receive a survivor benefit if he predeceased her.
Goodyear denied his request, saying that under the 1991 agreement the benefit was only available to his wife at that time.
Mr. Watkins appealed Goodyear's decision to the ERISA Advisory Council/Pension Board under the Employee Retirement Income Security Act.
In December 2016, the EAC/Pension Board affirmed Goodyear's position that there was no provision under Goodyear's pension plan for survivor benefits for any spouse other than the spouse who was living when the pension benefits began.
However, the Pension Board also informed Mr. Watkins that he could file suit under ERISA to seek judicial review of his claim, which he did in February 2017.
In granting summary judgment to Goodyear April 26, Alabama Judge Virginia Emerson Hopkins cited a 1989 Supreme Court case, Firestone Tire & Rubber Co. v. Bruch.
Firestone, Ms. Hopkins wrote, established three standards for courts to review an ERISA plan decision:
- When the plan does not grant discretion to the plan administrator;
- When the administrator's actions are arbitrary and capricious; or
- When there is "heightened arbitrary and capricious" because the administrator has a conflict of interest.
Mr. Watkins' appeal did not apply to any of these arguments, but consisted only of a statement of facts and two exhibits, Ms. Hopkins wrote.
"[Mr.] Watkins has failed to raise any developed argument to convince the court that Goodyear was de novo wrong," she wrote.
