Jakimas v. Hoffmann-La Roche, Inc.

Summary

The United States Court of Appeals for the Third Circuit affirmed summary judgment for Hoffmann-La Roche, Inc. and Johnson Controls World Services, Inc. in claims arising from the outsourcing and termination of former Roche employees. The court held that a claim under ERISA § 510 accrues when the employer decides to terminate the employee and provides notice of the pending termination, rather than on the actual termination date. The court also upheld judgment on the ERISA and New Jersey Law Against Discrimination claims.

Holdings

1. An ERISA § 510 claim based on termination accrues when the employer makes the decision to terminate and informs the employee of the pending termination, not when the termination becomes effective.
2. The claims of all appellants other than Michael Meechan were time-barred because they received actual notice of Roche's decision to terminate them before November 1, 1997, and the complaint was not filed until November 1, 1999.
3. Summary judgment based on the release was properly denied because genuine issues of material fact existed concerning whether Meechan knowingly and voluntarily accepted the release, including whether he understood the tax consequences of the nontransferability of his Roche 401(k) funds.
4. The common-law tender-back and ratification doctrines do not bar an ERISA § 510 claim merely because the employee retained severance consideration received under a release.
5. Meechan established a prima facie case of specific intent to interfere with pension benefits, but failed to show that Roche's legitimate technical and financial reasons for outsourcing were pretextual; summary judgment for the defendants was therefore proper.
6. Meechan failed to establish a prima facie NJLAD age-discrimination claim because he presented no evidence that younger employees were treated more favorably; termination to avoid pension benefits, without proof that age was a determinative factor, is insufficient.

Questions Presented

1. When does an ERISA § 510 claim based on an unlawful termination accrue: when the employee receives actual notice of the pending termination or when the termination becomes effective?
2. Whether Roche provided actual notice of the plaintiffs' terminations before the two-year limitations period expired.
3. Whether Roche's release and tender-back/ratification defenses barred Michael Meechan's claims.
4. Whether Meechan presented sufficient evidence of specific intent to interfere with pension benefits under ERISA § 510 and, after defendants articulated legitimate reasons for outsourcing, sufficient evidence of pretext.
5. Whether Meechan established a prima facie age-discrimination claim under the NJLAD in the context of an outsourcing or reduction in force.

Disposition

affirmed