ERISA-Eighth Circuit Upholds Plan’s Determination Of The Amount Of A Participant’s Pension Benefit

In Ingram v. Terminal Railroad Association of St. Louis Pension Plan for Nonschedule Employees, No. 14-3589 (8th Cir. 2016), in 2006, Theodore Ingram was employed by Union Pacific Railroad (“Union Pacific”) and living in Los Angeles. On July 1, he was hired to be the Superintendent of Transportation of the Terminal Railroad Association of St. Louis (“Terminal”) and moved to St. Louis. Ingram elected to receive early retirement benefits from Union Pacific beginning January 1, 2010. When he retired from Terminal at the end of 2010, he became eligible for retirement benefits under Terminal’s Pension Plan for Nonschedule Employees (the “Plan”).

In this action under § 502(a)(1)(B) of ERISA, Ingram alleges that the Plan erroneously determined his pension benefits by (i) excluding a 2006 sign-on bonus from pension-qualifying earnings and (ii) improperly inflating the offset for retirement benefits Ingram receives from Union Pacific. Reviewing the Plan’s decision for abuse of discretion, the district court granted summary judgment in favor of the Plan, concluding that the administrator’s decisions were reasonable. Ingram appeals. The Eighth Circuit Court of Appeals reviewed and affirmed the district court’s ruling.

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