Williams v. The NFL Player Supplemental Disability Plan

I. BACKGROUND

1 Plaintiff sues the NFL Player Supplemental Disability Plan, but the gravamen of Plaintiff’s complaint concerns the terms of the Plan and the actions of the Board. See ECF No. 1. A. Factual Background 1 1. The Bert Bell/Pete Rozelle NFL Player Retirement Plan 2 The Bert Bell/Pete Rozelle NFL Player Retirement Plan (“the Plan”) is an employee 3 benefit plan providing retirement, disability, and related benefits to eligible professional football 4 players. ECF No. 1 ¶ 2 (“Compl.”). According to the Complaint, the Plan is an “employee benefit 5 plan” within the meaning of Section 3(3) of the Employee Retirement Income Security Act of 6 1974 (“ERISA”), 29 U.S.C. § 1002(3), and a pension benefit plan under Section 3(2) of ERISA, 7 29 U.S.C. § 1002(2). Id. The Board is the Plan’s named fiduciary and plan administrator, id. ¶ 3, 8 and the Board has discretionary authority to interpret the Plan and determine all claims for 9 benefits, ECF No. 14-1, Ex. A § 8.2.2 10 The Plan provides four categories for total and permanent disability benefits (“T&P 11 benefits”), and two are relevant here: Active Football benefits and Football Degenerative benefits. 12 Id.…