Mendez v. Teachers Insurance & Annuity Ass'n

982 F.2d 783 (2d Cir. 1992) · United States Court of Appeals for the Second Circuit · December 28, 1992

Summary

The Second Circuit affirmed a judgment awarding Carmen Mendez annuity proceeds and attorney’s fees, costs, and disbursements in an ERISA dispute. The court held that TIAA-CREF unreasonably delayed commencing an interpleader action and therefore was not entitled to discharge from liability or attorney’s fees. The court also upheld the fee award to Mendez and affirmed the denial of prejudgment interest.

Holdings

  1. A stakeholder that satisfies the statutory prerequisites for interpleader may nevertheless be denied discharge under 28 U.S.C. § 2361 when its unreasonable delay in commencing the action is accompanied by circumstances implying bad faith. TIAA-CREF's unreasonable delay justified denial of discharge.
  2. The district court did not abuse its discretion by awarding Mendez attorney's fees, costs, and disbursements under 29 U.S.C. § 1132(g)(1), or by denying TIAA-CREF's request for fees.
  3. The district court properly awarded Mendez $20,190 in attorney's fees, costs, and disbursements.
  4. Prejudgment interest is discretionary in an ERISA action and should be awarded only when fair, equitable, and necessary to fully compensate the wronged party; Mendez was not entitled to additional prejudgment interest.

Questions Presented

  1. Whether TIAA-CREF was entitled to discharge from further liability under 28 U.S.C. § 2361 despite delaying commencement of the interpleader action.
  2. Whether the district court properly awarded Mendez attorney's fees, costs, and disbursements under ERISA and denied attorney's fees to TIAA-CREF.
  3. Whether the amount of Mendez's attorney's-fee award was excessive.
  4. Whether Mendez was entitled to prejudgment interest on the annuity proceeds.

Disposition

affirmed

Cases Cited (10)

  • New York Life Ins. Co. v. Connecticut Dev. Auth., 700 F.2d 91 (2d Cir. 1983)(followed)
  • Mendez v. Teachers Ins. and Annuity Ass'n, 789 F. Supp. 139 (S.D.N.Y. 1992)(affirmed)
  • Chambless v. Masters, Mates & Pilots Pension Plan, 815 F.2d 869 (2d Cir. 1987)(followed)
  • Ford v. New York Central Teamsters Pension Fund, 642 F.2d 664 (2d Cir. 1981) (per curiam)(followed)
  • Ford v. New York Central Teamsters Pension Fund, 506 F. Supp. 180 (W.D.N.Y. 1980)(followed)
  • Chambless v. Masters, Mates & Pilots Pension Plan, 885 F.2d 1053 (2d Cir. 1989), cert. denied, 110 S. Ct. 2587 (1990)(followed)
  • Clarke v. Frank, 960 F.2d 1146 (2d Cir. 1992)(followed)
  • DiFilippo v. Morizio, 759 F.2d 231 (2d Cir. 1985)(followed)
  • Katsaros v. Cody, 744 F.2d 270 (2d Cir. 1984), cert. denied, 469 U.S. 1076 (1984)(followed)
  • Wickham Contracting v. Local Union No. 3, IBEW, 955 F.2d 831 (2d Cir. 1992), cert. denied, 113 S. Ct. 394 (1992)(followed)

Cited In (0)

No citing cases on record yet.

Download CaseDownload Case DataDownload Case and DataDownload AI Instructions

Court Document

Open PDF
Loading document…

More from Second Circuit