Anderson v. Suburban Teamsters of Northern Illinois Pension Fund Board of Trustees
Filed December 1, 2009
Cite as 07-15532

Formula for Changing Benefits, Valid

Bruce Anderson was employed as a mechanic. He suffered from an on-the-job knee injury and was diagnosed with osteoarthritis. Consequently, he stopped working and went back to school. Unable to find a computer related job, Anderson worked as a truck driver. However, he stopped working due to pain from previous injury. Subsequently, he applied with the Suburban Teamsters of Northern Illinois Pension Fund (the Fund) for disability benefits under its pension plan (the Plan).

The Suburban Teamsters of Northern Illinois Pension Fund Board of Trustees (the Trustees) administered the Plan which was made up of both employer and employees representatives. The Plan provided two ways of computing disability benefit.

When Anderson applied for benefits, the Trustees responded that his disability benefits would be based on those Benefits Credits he actually earned while he was still working. The Trustees also applied the Qualified Domestic Relations Order (QDRO) during Anderson’s divorce proceedings.

Anderson appealed the partial denial as well as QDRO reduction. When the appeal was denied, Anderson filed a complaint in the Arizona District Court.

The court decided in favor of the Trustees.

The denial of the motion for new trial prompted Anderson to appeal the case with the United States of Court of Appeals for the Ninth Circuit.

The appeals court, in deciding in favor of the Trustees, made the following findings:

• The Trustees did not abuse their discretion in determining the date of employee’s disability when they have a reasonable basis to conclude that the employee was not totally and permanently disabled as of the date employee claimed.
• The benefits granted to Anderson’s wife were valid. This was because the QDRO allowed ex-wife to begin receiving pension payments at ex-husband's earliest retirement age. Hence, ex-wife was allowed to be paid even if husband was still working and that the husband could not share in any benefits allocated to wife.