Canseco v. Construction Laborers Pension Trust for Southern California, 93 F.3d 600 (9th Cir. 1996) - After working 30 years, plaintiff (one of a class of plaintiffs) became permanently disabled and retired at age 56. He applied for retirement benefits, which the plan administrator denied because the records erroneously indicated that plaintiff had worked only 14 years. Under the plan, pension benefits would vest only after 15 years of service and when the participant attained at least the age of 62. Some time during his retirement, the Ninth Circuit held in a related case that the plan's 15 years of service requirement was arbitrary and capricious, and the plan amended its requirement to 10 years. At that time, the plan notified plaintiff that he might be eligible for benefits. Upon reviewing his file, the trustee discovered that he actually worked thirty years. Since he met the service requirement, he became fully eligible for benefits when he reached the age 62. However, because plaintiff did not apply for benefits when he turned 62, the plan awarded retroactive benefits only to the time plaintiff reached age 65. According to the plan administrator's interpretation, although plaintiff was eligible for benefits at age 62, he was not entitled to them because he did not apply. However, at age 65, the benefits were automatic. On appeal, the Ninth Circuit rejected this reading of the plan and reversed the district court's grant of summary judgment to the defendant. The plaintiff raised three arguments on appeal, but the court only addressed plaintiff's first claim: that under Sec. 1132(a)(1)(B), the terms of the plan entitle them to retroactive benefits to the date they became eligible for those benefits. The court found by reviewing the plan that three things were required to meet eligibility: (1) 15 years of employment; (2) attainment of age 62; and (3) 700 "covered hours" of employment. This clear and unambiguous language entitled plaintiffs to retire on the plan's regular pension. Another provision in the plan stated that in order to receive benefits, the participant must submit an application. However, the court held that the application requirement did not affect the eligibility, but only determined when the participant would begin receiving benefits to which he was entitled. There was nothing in the plan that provided that an employee's failure to submit an application would result in the retroactive loss of benefits for which that employee was eligible. The court saw the application as nothing more than a procedural formality that would trigger the employee's "receipt" of benefits, and did not substantively affect their right to benefits. Moreover, the court held that plan administrator could not imply the added application requirement for eligibility which clashes with the unambiguous terms of the plan. Finally, the court opted not to remand the matter because this was not a matter of misrepresentation. It held that reevaluation of the merits of the retirees' claim was not required since there were no factual determinations to be made. It also awarded plaintiff attorneys' fees because they prevailed on their claims and there were no special circumstances that would make the award of fees unjust.
