Ingersoll-Rand Co. v. McClendon

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Ingersoll-Rand Co. v. McClendon
Seal of the United States Supreme Court.svg
Argued October 9, 1990
Decided December 3, 1990
Full case nameIngersoll-Rand Company v. McClendon
Citations498 U.S. 133 ( more )
111 S. Ct. 478; 112 L. Ed. 2d 474
Court membership
Chief Justice
William Rehnquist
Associate Justices
Byron White  · Thurgood Marshall
Harry Blackmun  · John P. Stevens
Sandra Day O'Connor  · Antonin Scalia
Anthony Kennedy  · David Souter
Case opinions
MajorityO'Connor, joined by unanimous (parts I and II-B); Rehnquist, White, Scalia, Kennedy, Souter (part II-A)
Laws applied
Employee Retirement Income Security Act of 1974, 29 U.S.C.   § 1001 et seq.

Ingersoll-Rand Co. v. McClendon, 498 U.S. 133 (1990), is a US labor law case, concerning the scope of labor rights in the United States. [1]

Labor rights or workers' rights are a group of legal rights and claimed human rights having to do with labor relations between workers and their employers, usually obtained under labor and employment law. In general, these rights' debates have to do with negotiating workers' pay, benefits, and safe working conditions. One of the most central of these rights is the right to unionize. Unions take advantage of collective bargaining and industrial action to increase their members' wages and otherwise change their working situation. Labor rights can also take in the form of worker's control and worker's self management in which workers have a democratic voice in decision and policy making. The labor movement initially focused on this "right to unionize", but attention has shifted elsewhere.

United States Federal republic in North America

The United States of America (USA), commonly known as the United States or America, is a country composed of 50 states, a federal district, five major self-governing territories, and various possessions. At 3.8 million square miles, the United States is the world's third or fourth largest country by total area and is slightly smaller than the entire continent of Europe's 3.9 million square miles. With a population of over 327 million people, the U.S. is the third most populous country. The capital is Washington, D.C., and the largest city by population is New York City. Forty-eight states and the capital's federal district are contiguous in North America between Canada and Mexico. The State of Alaska is in the northwest corner of North America, bordered by Canada to the east and across the Bering Strait from Russia to the west. The State of Hawaii is an archipelago in the mid-Pacific Ocean. The U.S. territories are scattered about the Pacific Ocean and the Caribbean Sea, stretching across nine official time zones. The extremely diverse geography, climate, and wildlife of the United States make it one of the world's 17 megadiverse countries.

Contents

Facts

Mr. McClendon claimed his job was terminated to prevent his pension benefits from "vesting" (full rights becoming irrevocable if the employment contract ended) under the Employee Retirement Income Security Act of 1974. He argued this violated Texas state law public policy and sought damages for wrongful termination, mental anguish, including punitive damages. He sought to avoid a question of preemption of his claim by ERISA 1974 §514(a), [2] by not claiming lost pension benefits, or referring to pension plan details, and instead basing a claim solely upon state law.

Employee Retirement Income Security Act of 1974

The Employee Retirement Income Security Act of 1974 (ERISA) is a federal United States tax and labor law that establishes minimum standards for pension plans in private industry. It contains rules on the federal income tax effects of transactions associated with employee benefit plans. ERISA was enacted to protect the interests of employee benefit plan participants and their beneficiaries by:

Texas State of the United States of America

Texas is the second largest state in the United States by both area and population. Geographically located in the South Central region of the country, Texas shares borders with the U.S. states of Louisiana to the east, Arkansas to the northeast, Oklahoma to the north, New Mexico to the west, and the Mexican states of Chihuahua, Coahuila, Nuevo León, and Tamaulipas to the southwest, while the Gulf of Mexico is to the southeast.

Punitive damages, or exemplary damages, are damages assessed in order to punish the defendant for outrageous conduct and/or to reform or deter the defendant and others from engaging in conduct similar to that which formed the basis of the lawsuit. Although the purpose of punitive damages is not to compensate the plaintiff, the plaintiff will receive all or some of the punitive damages award.

The Texas Courts held that he had a claim.

Judgment

Justice O’Connor held that Mr McClendon’s claim was pre-empted. The Texas public policy ‘referred to’ a pension plan, to protect its integrity against employer misconduct. The state action would also be preempted by implication as it conflicted potentially by the anti-discrimination provisions of ERISA (29 USC §1140).

Sandra Day OConnor Former Associate Justice of the Supreme Court of the United States

Sandra Day O'Connor is a retired Associate Justice of the Supreme Court of the United States, who served from her appointment in 1981 by President Ronald Reagan until her retirement in 2006. She was the first woman to serve on the Court.

O'Connor J said the following, with which the whole court concurred.

B

Even if there were no express pre-emption in this case, the Texas cause of action would be pre-empted because it conflicts directly with an ERISA cause of action. McClendon's claim falls squarely within the ambit of ERISA § 510, which provides:

"It shall be unlawful for any person to discharge, fine, suspend, expel, discipline, or discriminate against a participant or beneficiary for exercising any right to which he is entitled under the provisions of an employee benefit plan . . . or for the purpose of interfering with the attain- ment of any right to which such participant may become entitled under the plan. . . ." 29 U.S.C. § 1140 (emphasis added).

By its terms § 510 protects plan participants from termination motivated by an employer's desire to prevent a pension from vesting. Congress viewed this section as a crucial part of ERISA because, without it, employers would be able to circumvent the provision of promised benefits. S.Rep. No. 93-127, pp. 35-36 (1973); H.R.Rep. No. 93-533, p. 17 (1973). We have no doubt that this claim is prototypical of the kind Congress intended to cover under § 510.

This meant, in the court's view, that a civil action under §502(a) - not including punitive damages, potentially available in state law - was the only available remedy.

In addition, Justice O'Connor offered an opinion that McClelland's claim was preempted in general. Justice Rehnquist, Justice White, Justice Scalia, Justice Kennedy, Justice Souter joined. Justice Marshall, Justice Blackmun and Justice Stevens offered no view.

William Rehnquist Chief Justice of the United States

William Hubbs Rehnquist was an American lawyer and jurist who served on the Supreme Court of the United States for 33 years, first as an Associate Justice from 1972 to 1986, and then as the 16th Chief Justice of the United States from 1986 until his death in 2005. Considered a conservative, Rehnquist favored a conception of federalism that emphasized the Tenth Amendment's reservation of powers to the states. Under this view of federalism, the court, for the first time since the 1930s, struck down an act of Congress as exceeding its power under the Commerce Clause.

Byron White Associate Justice of the U.S. Supreme Court, American football player

Byron Raymond "Whizzer" White was an Associate Justice of the Supreme Court of the United States from April 12, 1962 to June 28, 1993.

Antonin Scalia American judge

Antonin Gregory Scalia was an Associate Justice of the Supreme Court of the United States from 1986 until his death in 2016. Appointed to the Court by President Ronald Reagan in 1986, Scalia was described as the intellectual anchor for the originalist and textualist position in the Court's conservative wing.

A

[...]

The key to § 514(a) is found in the words "relate to." Congress used those words in their broad sense, rejecting more limited pre-emption language that would have made the clause "applicable only to state laws relating to the specific subjects covered by ERISA." Shaw, supra, 463 U.S., at 98, 103 S.Ct., at 2900-01. Moreover, to underscore its intent that § 514(a) be expansively applied, Congress used equally broad language in defining the "State law" that would be pre-empted. Such laws include "all laws, decisions, rules, regulations, or other State action having the effect of law." § 514(c)(1), 29 U.S.C. § 1144(c)(1).

"A law 'relates to' an employee benefit plan, in the normal sense of the phrase, if it has a connection with or reference to such a plan." Shaw, supra, at 96-97, 103 S.Ct., at 2900. Under this "broad common-sense meaning," a state law may "relate to" a benefit plan, and thereby be pre-empted, even if the law is not specifically designed to affect such plans, or the effect is only indirect. Pilot Life, supra, 481 U.S., at 47, 107 S.Ct., at 1552-53. See also Alessi v. Raybestos-Manhattan, Inc. , supra, 451 U.S., at 525, 101 S.Ct., at 1907. Pre-emption is also not precluded simply because a state law is consistent with ERISA's substantive requirements. Metropolitan Life Ins. Co. v. Massachusetts , [1985] USSC 140; 471 U.S. 724, 739[1985] USSC 140; 105 S.Ct. 2380, 2388-89[1985] USSC 140; 85 L.Ed.2d 728 (1985).

Notwithstanding its breadth, we have recognized limits to ERISA's pre-emption clause. In Mackey v. Lanier Collection Agency & Service, Inc. , 486 U.S. 825, 108 S.Ct. 2182, 100 L.Ed.2d 836 (1988), the Court held that ERISA did not pre-empt a State's general garnishment statute, even though it was applied to collect judgments against plan participants. Id., at 841, 108 S.Ct., at 2191. The fact that collection might burden the administration of a plan did not, by itself, compel pre-emption. Moreover, under the plain language of § 514(a) the Court has held that only state laws that relate to benefit plans are pre-empted. Fort Halifax Packing Co. v. Coyne , 482 U.S. 1, 23[1987] USSC 99; 107 S.Ct. 2211, 2223-24[1987] USSC 99; 96 L.Ed.2d 1 (1987). Thus, even though a state law required payment of severance benefits, which would normally fall within the purview of ERISA, it was not pre-empted because the statute did not require the establishment or maintenance of an ongoing plan. Id., at 12, 107 S.Ct., at 2217-18.

Neither of these limitations is applicable to this case. We are not dealing here with a generally applicable statute that makes no reference to, or indeed functions irrespective of, the existence of an ERISA plan. Nor is the cost of defending this lawsuit a mere administrative burden. Here, the existence of a pension plan is a critical factor in establishing liability under the State's wrongful discharge law. As a result, this cause of action relates not merely to pension benefits, but to the essence of the pension plan itself.

We have no difficulty in concluding that the cause of action which the Texas Supreme Court recognized here—a claim that the employer wrongfully terminated plaintiff primarily because of the employer's desire to avoid contributing to, or paying benefits under, the employee's pension fund—"relate[s] to" an ERISA-covered plan within the meaning of § 514(a), and is therefore pre-empted.

[...]

McClendon argues that § 514(c)(2)'s limiting language causes § 514(a) to pre-empt only those state laws that affect plan terms, conditions, or administration. Since the cause of action recognized by the Texas court does not focus on those items but rather on the employer's termination decision, McClendon claims that there can be no pre-emption here.

The flaw in this argument is that it misreads § 514(c)(2) and consequently misapprehends its purpose. The ERISA definition of "State" is found in § 3(10), which defines the term as "any State of the United States, the District of Columbia, Puerto Rico, the Virgin Islands, American Samoa, Guam, Wake Island, and the Canal Zone." 29 U.S.C. § 1002(10). Section 514(c)(2) expands, rather than restricts, that definition for pre-emption purposes in order to "include " state agencies and instrumentalities whose actions might not otherwise be considered state law. Had Congress intended to restrict ERISA's pre-emptive effect to state laws purporting to regulate plan terms and conditions, it surely would not have done so by placing the restriction in an adjunct definition section while using the broad phrase "relate to" in the pre-emption section itself.

[...]

The conclusion that the cause of action in this case is pre-empted by § 514(a) is supported by our understanding of the purposes of that provision. Section 514(a) was intended to ensure that plans and plan sponsors would be subject to a uniform body of benefits law; the goal was to minimize the administrative and financial burden of complying with conflicting directives among States or between States and the Federal Government. Otherwise, the inefficiencies created could work to the detriment of plan beneficiaries.

See also

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References

  1. Ingersoll-Rand Co. v. McClendon, 498 U.S. 133 (1990).
  2. 29 U.S.C.   § 1144(a) .