Dresel v. Pension Plan of the Pacific Northwest Laboratories, Battelle Memorial Institute

MEMORANDUM

In this Employee Retirement Income Security Act (ERISA) case, the Pension Plan of the Pacific Northwest Laboratories, Battelle Memorial Institute (the Plan) appeals the grant of summary judgment in favor of claimant Peter Dresel and the denial of the Plan’s cross-motion for summary judgment. The Plan contends that it did not abuse its discretion in denying Dresel Early Retirement Benefits (ERB) under its Pension Plan. Dresel cross-appeals, arguing that the district court applied an overly deferential standard in reviewing the Plan’s decision.

Whether the district court was overly deferential to the Plan does not require remand. Although the district court could have tempered its abuse of discretion standard of review with some skepticism because the plan administrator both paid benefit awards and determined eligibility for benefits, we affirm because the district court’s holding that the Plan abused its discretion survives under even the most deferential standard of review.

The district court properly held that the Plan abused its discretion in denying Dre-sel ERB. Under a straightforward application of the abuse of discretion standard, a plan administrator’s…