Federal District Court Holds that Equitable Estoppel is not Viable Theory in Pension Plan Cases

Two participant-plaintiffs in a multiemployer pension plan each received a notice from the plan administrator that it was rescinding certain benefits and requesting approximately $40,000 in repayments. In granting defendant’s motion to dismiss the plaintiffs‘  equitable estoppel claim, the federal district court held that equitable estoppel may be a viable theory in ERISA cases involving welfare plans, but is not a viable theory for cases regarding ERISA pension benefit plans, especially in the absence of evidence of ambiguity in the plan provisions. Crawford v. PIUMPF, No. 3:10-00628 (M.D.Tenn. May 23, 2011).

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