Employee Benefits-Second Circuit Rules That State Law Claim Pertaining To An Employee Benefit Plan Is Subject To The Three Year Statute Of Limitations Found In ERISA  

In Pruter v. Local 210’s Pension Trust Fund, No. 16-733-cv (2nd Cir. 2017), the Plaintiffs, former employees of World Airways, Inc., appeal from the February 8, 2016 memorandum and order of the United States District Court for the Southern District of New York (Torres, J.) dismissing their complaint seeking damages under state law for fraud, breach of contract and violation of an employee benefit plan.

Upon analyzing the case, the Second Circuit Court of Appeals (the “Court”) said that we agree with the district court that plaintiffs’ state law claims arise under the RLA and are thus preempted.  As those claims bear a close resemblance to claims brought pursuant to ERISA, however, we find it appropriate to borrow and apply ERISA’s three-year statute of limitations rather than the six-month limitations period the district court borrowed from Section 10(b) of the National Labor Relations Act (“NLRA”).  The Court therefore vacated the district court’s dismissal (on limitations grounds) of the RLA claims brought against Local 210 and remand for further consideration of that claim consistent with this opinion. The Court affirmed the district court’s opinion in all other respects.