CA1: plan interpretation and ERISA

Otero-Carrasquillo v. Pharmacia Corp., No. 05-2373.  This is an “interesting” ERISA case.  The First affirms the District Court’s granting of summary judgment, and assessment of civil penalties against Pharmacia for failing to comply with ERISA's reporting and disclosure provision.  In this case, the question is whether an administrator abused his discretion by denying him severance benefits.  As a matter of plan interpretation, the First says that the administrator was relying on the right verison of the law, and his decision wasn’t an abuse of discretion.  The court concludes that the plaintiffs IIED and “fraudulent inducement” claims are preempted by ERISA.