United States District Court, S.D. Indiana, Evansville Division
ENTRY ON DEFENDANT'S MOTION TO DISMISS
RICHARD L. YOUNG, District Judge.
Plaintiff Jill Sandefur alleges Defendant Iron Workers St. Louis District Council Pension Fund ("Iron Workers") violated the Employee Retirement Income Security Act ("ERISA") and committed fraud when Iron Workers refused to provide her with retirement benefits. Iron Workers moves to dismiss the Complaint for failure to state a cause of action upon which relief can be granted pursuant to Federal Rule of Civil Procedure 12(b)(6). For the reasons set forth below, Iron Workers' motion is GRANTED in part and DENIED in part.
Jill Sandefur married Larry Sandefur, a participant in Iron Workers St. Louis District Council Pensions Trust, on January 27, 2000. (Complaint ¶¶ 10, 11). Mr. Sandefur retired on or around September 1, 2000, and passed away on February 8, 2006. ( Id. ¶¶ 12, 13).
Sandefur filed a benefits claim with Iron Workers following her husband's death. ( Id. ¶ 14.) Iron Workers denied her claim, ruling on the basis that Sandefur did not constitute a "Qualified Spouse." Id. The Pension Plan notes that a Qualified Spouse may claim pension "if the Participant and the Spouse became married within the year immediately preceding the date the Participant's pension payments start and they were married for at least a year before his death." (Exhibit A, Filing No. 18, at ECF p. 47).
Sandefur subsequently made multiple requests for full copies of the Pension Plan but claims Iron Workers sent prepared summaries instead. (Complaint ¶ 20.) Additionally, Iron Workers alleges that Sandefur signed a Rejection of the Husband and Wife Option in August of 2000, thereby waiving her future rights to her husband's pension. ( Id. ¶ 17.) Sandefur contends that this document contains her forged signature. ( Id. ¶ 18.)
Sandefur filed this lawsuit on December 30, 2014. ( Id. ¶ 1.) In her Complaint, she alleges that Iron Workers violated ERISA by not giving her adequate notice in writing for denying her claims, that she is entitled to lost benefits with interest, compensatory and punitive damages, and attorney fees. (Requested Relief, Filing No. 1 at 6.) In response, Iron Workers filed a motion to dismiss the Complaint.
II. Standard of Review
A defendant may move for dismissal when the plaintiff's pleading fails to state a claim upon which relief can be granted. Fed R. Civ. P. 12(b)(6). Courts accept all well pled facts as true and draw all permissible inferences in favor of the plaintiff in reviewing Rule 12(b)(6) motions. Agnew v. Nat'l Collegiate Athletic Ass'n, 683 F.3d 328, 334 (7th Cir. 2012). However, "mere conclusory statements do not suffice." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A plaintiff's obligation to support his claim for relief "requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do." Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 554 (2007). Courts should not dismiss complaints simply because there is doubt as to whether the plaintiff can prove all factual allegations. Id. at 556. Rather, complaints must contain enough facts "to raise a reasonable expectation that discovery will reveal evidence." Id.
A. ERISA Violation Claims
Iron Workers moves to dismiss the ERISA violation claims under multiple theories. First, Iron Workers asserts that the Complaint fails to satisfy Rule 8 of the Federal Rules of Civil Procedure. Next, it argues that the claims are barred by the statute of limitations and the limitations period contained in the Plan. Iron Workers then argues that the claims are barred because she failed to exhaust her administrative remedies. Finally, Iron Workers argues that relevant case law prohibits Sandefur's forgery claim. The court will discuss each in turn.
1. Does the Complaint Satisfy Rule 8?
Rule 8 requires that complaints contain "a short and plain statement of the claim showing that the pleader is entitled to relief." Fed.R.Civ.P. 8(a)(2). The complaint must be sufficiently plausible such that it shows "more than a sheer possibility that a defendant has acted unlawfully." Iqbal, 556 U.S. at 678. Essentially, "Rule 8 does not unlock the doors of discovery for a plaintiff armed with nothing more than conclusions." ...