No right to jury trial on ERISA and LMRA claims for retiree health benefits

Winnett v Caterpillar, Inc, ____F.Supp.2d____(M.D. Tenn.November 16, 2009), is an important decision to be aware of. The court held that retirees and beneficiaries of Caterpillar, who sought declaratory and injunctive relief for lifetime no-cost retiree health care benefits, were not entitled to a jury trial for claims under ERISA and the Labor Management Relations Act (LMRA).The court observed that under Sixth Circuit precedent, there is no right to a jury trial in ERISA and LMRA cases involving claims for vested retiree health benefits. Although the employees sought monetary damages for reimbursement of premiums, co-payments and other costs they may have incurred, those claims were intertwined with their primary goal of obtaining a declaration that they were entitled to no-cost lifetime retiree health benefits. Therefore, the fundamental requested relief was equitable, and there is no constitutional right to a trial by jury on claims under the LMRA or ERISA. This case has had a long history in the courts. In May 2007, the district court denied Caterpillar's motion to dismiss the lawsuit. A few months later, the court granted the plaintiffs' motion for class certification. And, in January 2009, the Sixth Circuit ruled that a 1988 labor contract between Caterpillar and the United Auto Workers does not guarantee lifetime retiree healthcare benefits for active workers when they become eligible for pensions before their actual retirement.

Mitchell H. Rubinstein