Thursday, November 7, 2013

Brumm v. Bert Bell NFL Retirement Plan case brief

Brumm v. Bert Bell NFL Retirement Plan case brief summary
995 F.2d 1433 (1993)


CASE SYNOPSIS
Appellant applicant challenged the order of the United States District Court for the Western District of Missouri that granted appellee retirement plan and board's summary judgment motion in appellant's action under 29 U.S.C.S. § 1132(a)(1) for full disability benefits as a vested participant in appellee plan, which was governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C.S. § 1001 et seq.

CASE FACTS
Appellant applicant played football for NFL teams, sustaining several injuries during his career. He was a vested participant in appellee NFL retirement plan that was governed by The Employee Retirement Income Security Act of 1974 (ERISA) 29 U.S.C.S. § 1001 et seq.Appellant applied for disability benefits. Appellee plan's board denied appellant the full disability benefits that he sought. Appellant then brought suit in the district court against appellee plan and board members under 29 U.S.C.S. § 1132(a)(1). The district court granted appellees' summary judgment motion. Appellant challenged that order.

DISCUSSION
  • On appeal, the court's review was hindered by appellee board's failure to provide adequate written notice to appellant of the reasons for the denial of benefits as required by ERISA. 
  • Appellee failed to set forth in writing the specific reasons for its denial of benefits, written in a manner calculated to be understood by any participant, as required under ERISA, 29 U.S.C.S. § 1133. 
  • The court reversed the summary judgment because appellee board's presumed interpretation of appellee plan was unreasonable and constituted an arbitrary and capricious denial of benefits.

CONCLUSION

The court reversed and remanded the district court order that granted summary judgment to appellee retirement plan and board because appellees' interpretation of the plan constituted an arbitrary and capricious denial of benefits to appellant applicant.

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