Alaska Employment Law

U. S. District Judge Ralph Beistline has held that the Teamster Affiliates Pension Plan is equitably estopped from retracting its Administrator’s representation of a participant’s benefit amount.

Jacqueline Bloom worked in the Fairbanks office of Teamsters Local 959 from 1970 through 2004.  She qualified for a pension under both the Alaska Teamster-Employer Pension Trust and the Teamster Affiliates Pension Plan (TAPP).  Before she retired, Bloom asked the Administrator whether her TAPP benefit would be reduced because of her eligibility under the regular Teamster Plan.  The Administrator orally and in writing assured her that she would suffer no reduction.  When she actually applied for the benefits, however, the TAPP Administrator, and then the Trustees) substantially reduced her benefit.

Bloom sued under promissory estoppel and fiduciary breach theories.  In his August 5th Order, Beistline resolved the estoppel claim (under equitable estoppel caselaw).

Beistline held that the TAPP plan documents contained an “ambiguity” about the interplay between TAPP and other pension benefits (the term of art is “aggregation”).  Whether through the (unidentified) TAPP attorney’s “scrivener’s error,” or misinterpretation of IRC § 415(f)(3)(A),  the documents did not clearly require aggregation of benefits.  Beistline then found that Bloom relied on the misrepresentation and that she was ignorant of the true facts.  Beistline did not directly address TAPP’s argument that estoppel would require the Plan to violate the IRC.

Beistline emphasized that Bloom did not make the (more usual) claim that the Administrator had miscalculated the benefits.

Although the letters contained disclaimers that the numbers were merely estimates and subject to change, this case is unique in that Bloom specifically asked about aggregation, a question that required a straightforward “yes” or “no” answer.

Beistline also ordered interest on late payments.

Remaining are Bloom’s claims for fiduciary breach, failure to follow claim procedures, and failure to provide required information.

Bloom v. Teamster Affiliates Pension Plan, 2008 WL 3200763 (D.Alaska Aug. 5, 2008)

Ron Bliss of Bliss, Wilkins & Clayton represents plaintiff Bloom.  Randall Simpson of Jermain Dunnagan & Owens represents defendant TAPP.