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.'"