Trujillo v. Cyprus Amax Minerals Co. Retirement Plan Committee, 203 F. 3d 733 (10th Cir. 2000)

Trujillo v. Cyprus Amax Minerals Co. Retirement Plan Committee, 203 F. 3d 733 (10th Cir. 2000)-Trujillo, a former employee of Cyprus Amax Minerals, filed suit.  He challenged a decision by the Retirement Plan Committee to reduce his disability retirement benefits by the total amount of a workers' compensation settlement without paying a pro rata share of attorney fees necessary to obtain the settlement.  The Plan provided that "the Disability Retirement Benefits payable to any Member shall be reduced by the amount of any worker's compensation benefits . . . payable to him."  Trujillo claimed that only the net settlement, i.e., the settlement amount minus fees and expenses, is "payable" to the worker.

Reviewing under an arbitrary and capricious standard, this court decided it would not set aside the benefit committee's decision.  The committee based its decision on a reasonable interpretation of the plan's terms.  Plan Administrators can reasonably interpret the phrase "worker's compensation benefits ... payable to him with respect to his disability" to encompass any amounts "capable of being paid," "justly due," or "legally enforceable" that arise out of a worker's disability.  This court declined to entertain Trujillo's public policy arguments, and also refused to consider his unjust enrichment claim.  It stated that the Circuit had held that plaintiff can only use the doctrine of unjust enrichment when it does not "override a contractual plan provision," and where its application "'would be consistent with ERISA's scheme and further its purposes.'"

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