SEAN F. COX, District Judge.
Plaintiff Mary Kern ("Plaintiff) filed this ERISA action challenging the administrative decision of Defendant Chrysler UAW Pension Plan denying her request for widow's pension benefits. Thereafter, the parties filed cross-motions for judgment on the administrative record. Those motions were referred to Magistrate Judge Mark A. Randon, pursuant to 28 U.S.C. § 636, for issuance of a report and recommendation.
On March 16, 2012, Magistrate Judge Randon issued a Report and Recommendation ("R&R"), wherein he recommends that the Court grant Defendant's Motion for Judgment on the Administrative Record and deny Plaintiff's Motion for Judgment on the Administrative Record. On March 30, 2012, Plaintiff filed written objections to the March 16, 2012 R&R. (Objections, D.E. No. 20). For the reasons that follow, the Court
John Kern was an employee of Chrysler LLC and a participant in the Chrysler UAW Pension Plan (the "Plan"). Mr. Kern married Plaintiff on April 19, 2004. (Doc. Entry No. 9, Administrative Record ("AR") at 12). Mr. Kern died on August 4, 2004. (AR at 4).
Sometime after Mr. Kern's death,
On February 22, 2009 — four years later — Plaintiff's counsel sent a letter to Benefit Express, a service provided for the Plan, stating that Plaintiff is qualified for, and should receive widow's pension benefits. (Id.). Benefit Express responded in a letter dated April 23, 2009, advising Plaintiff to complete and return a Retirement Plan Claim Initiation Form. (AR at 19-20). Benefit Express acknowledged that it received Plaintiff's Retirement Plan Claim Initiation Form on May 17, 2010. (AR at 33).
In a letter dated May 11, 2010, the Plan denied Plaintiff's claim for widow's pension benefits because the Surviving Spouse Option ("SSO") of the Plan required Plaintiff to be married to Mr. Kern for at least one year before she could be elected as a beneficiary under the SSO. (AR at 34). Mr. Kern and Plaintiff had been married for less than four months before his death. (AR at 34-35).
On July 8, 2012, Plaintiff appealed the Plan's denial of benefits to the Chrysler Group LLC — UAW Pension Board of Administration (the "Board"). (AR at 37). For the same reasons cited in the Plan's May 11, 2010 letter to Plaintiff, the Board denied Plaintiff's appeal. (AR at 42-43).
On May 4, 2011, Plaintiff filed her Complaint, pursuant to § 502(a)(1)(B), alleging that the Plan's denial of Plaintiff's widow's pension benefits was arbitrary and capricious.
Pursuant to FED. R. CIV. P. 72(b), a party objecting to the recommended disposition of a matter by a Magistrate Judge must file objections to the R&R. "The district judge must determine de novo any part of the magistrate judge's disposition that has been properly objected to. The district judge may accept, reject, or modify the recommended disposition; receive further evidence; or return the matter to the magistrate judge with instructions." Id.
In the R&R, Magistrate Judge Randon concluded that Defendant's interpretation that the Plan limits widow's pension benefits to marriages lasting at least a year (the "one-year marriage exception") was a rational interpretation of the Plan's provisions and was not arbitrary and capricious.
The Court can delineate three specific objections from Plaintiff's March 30, 2012 written objections. All of Plaintiff's objections are premised upon the assumption that the administrator did not draft a "one-year marriage exception" into the Plan when a participant dies, rather than retires, and that the R&R failed to address this omission. Plaintiff refers to this alleged omission as the "missing exception." Plaintiff's three objections are as follows: 1) The R&R did not account for and make "specific findings about the missing exception in order to support its finding of a rational interpretation;" 2) The R&R should not have accounted for "the administrator's interpretation relying upon plan language that is intended for a different fact scenario" [presumably, retirement]; and 3) The R&R does not "explain how the controlling law is overcome without a clear exception to joint and survivor annuity benefits when a participant dies prior to retirement."
Plaintiff essentially makes the same argument that was rejected by Magistrate Judge Randon — that the administrator's interpretation of the Plan such that it includes a "one-year marriage exception" to widow's pension benefits when a Plan participant dies — is not a proper interpretation of the Plan. This court finds that all three of Plaintiff's objections are without merit because the administrator's interpretation of the Plan as including a one-year marriage requirement to qualify for widow's pension benefits is not arbitrary and capricious. Defendant's interpretation of such an exception rational in light of the Plan's provisions. (R&R at 8).
ERISA's statutory provision for a Plan's marriage requirements provides:
29 U.S.C. § 1055(f). Thus, § 1055(f) permits Defendant to include a one-year marriage requirement for a spouse to qualify for widow's pension benefits.
The relevant language of Section (9)B of the Plan states:
(AR 161-162) (emphasis added). Thus, in addition to the age and years-of-service requirements of Section 9(B)(i), the deceased employee must have been eligible to make the election under Section (9)A in order for a spouse to qualify for a widow's pension. Section (9)A provides:
(AR at 157-58) (emphasis added). Based upon Section (9)B, widow's pension benefits are treated as if the employee retired on the date of his death. The widow is only entitled to the benefits if the employee made the election under Section (9)A. Therefore, under Section (9)A, Mr. Kern's widow's pension benefits election can only become effective on the first day of the month following the month in which his marriage to Plaintiff has been in effect for one year. Because Plaintiff married Mr. Kern only four months prior to his death, Mr. Kern's automatic election of the widow's pension benefit never took effect.
Based upon these provisions of the Plan, this Court agrees with Magistrate Judge Randon's conclusion that "Defendant rationally interpreted the language of the Plan." (R&R at 8). Accordingly, Plaintiff's objections that presume there is no one-year marriage requirement for widow's pension benefits are without merit.
For the reasons stated above,