Crawford v. La Boucherie Bernard Ltd.

Summary

The court holds that ERISA permits a participant’s beneficial interest in an employee benefit plan to be offset against a judgment for breaches of fiduciary duty to the plan, notwithstanding ERISA’s anti-alienation provision. It concludes that traditional trust principles support forfeiting or impounding a breaching trustee-beneficiary’s interest to compensate the plan and prevent the wrongdoer from benefiting from misconduct. The court also upholds the district court’s civil RICO judgment and treble damages against Bernard Goldstein.

Holdings

1. ERISA permits a court to offset a breaching fiduciary's beneficial interest in an ERISA plan against the fiduciary's judgment debt to the plan when the offset is necessary to remedy the fiduciary's depletion of plan assets.
2. The District Court properly applied its ERISA findings to the RICO claim because the same facts established both the ERISA fiduciary violations and the statutory predicate offense under 18 U.S.C. § 664.
3. A private civil RICO plaintiff need not establish a prior criminal conviction or a separate racketeering injury distinct from the injury caused by the predicate acts.
4. Summary judgment is not precluded merely because intent is ordinarily a jury question when intent may be inferred from objective facts.
5. The Court of Appeals lacked jurisdiction to review the merits of the underlying ERISA judgment because the notice of appeal was filed outside the applicable time limit and no extension was sought.

Questions Presented

1. Whether ERISA's anti-alienation provision prevents a court from offsetting a breaching fiduciary's beneficial interest in an ERISA plan against a judgment for losses caused by the fiduciary's breaches.
2. Whether the District Court properly applied findings made in the ERISA proceeding to establish liability under RICO.
3. Whether a prior criminal conviction or a separate racketeering injury was required for the civil RICO claim.
4. Whether summary judgment was improper because intent was a factual issue for a jury.
5. Whether the District Court abused its discretion by trebling the damages under RICO.
6. Whether the Court of Appeals had jurisdiction to review the underlying ERISA liability judgment after an untimely notice of appeal.

Disposition

affirmed