Eijinio Banuelos v. Construction Laborers' Trust Funds for Southern California

Eijinio Banuelos (“Banuelos”) filed the underlying complaint against the Construction Laborers’ Pension Trust for Southern California (“the Trust”), seeking to establish his right to receive a pension. The district court denied the parties’ cross-motions for summary judgment, relying on evidence that was not part of the administrative record to conclude that there was a genuine issue of material fact as to whether the Trust had adopted five-year vesting rules applicable to Banuelos. After a bench trial, the district court held that Banuelos was not entitled to five-year vesting.

Banuelos appeals the district court’s denial of his summary judgment motion, arguing that the district court erred by considering evidence outside the administrative record. We reverse the denial of Banuelos’s motion for summary judgment, vacate the subsequent judgment, and remand to the district court with instructions to remand to the plan administrator to calculate Banuelos’s pension.

I

FACTS AND PROCEEDINGS BELOW

A. The Pension Plan

The Trust is an express trust established in 1962. Pursuant to the terms of various collective bargaining agreements between the Southern California District Council…