Summary
The Superior Court of Pennsylvania reviewed SKF USA, Inc.'s interlocutory appeal from the denial of summary judgment in former employees' breach of oral contract action. The court held that the employees' claim for promised enhanced severance and pension-related benefits was only tenuously related to an ERISA plan and was therefore not preempted. The court affirmed the order denying summary judgment and noted a dissent.
Holdings
- The appellees' breach-of-oral-contract claim was not preempted by ERISA because its connection to the ERISA plan was only tenuous and incidental.
- Hooven did not control the case because it involved claims asserted under ERISA and an ancillary contract theory arising from an ERISA plan, whereas the appellees asserted an independent state-law claim based on an alleged oral promise.
Questions Presented
- Whether the appellees' Pennsylvania breach-of-oral-contract claim for enhanced severance benefits was preempted by ERISA.
- Whether the Third Circuit's decision in Hooven v. Exxon Mobil Corp. required summary judgment for SKF.
Disposition
affirmed
Cases Cited (10)
- Evans v. Sodexho, 946 A.2d 733 (Pa. Super. Ct. 2008)(followed)
- Scalice v. Pennsylvania Employees Benefit Trust Fund, 584 Pa. 161, 883 A.2d 429 (2005)(followed)
- Greenblatt v. Budd Co., 666 F. Supp. 735 (E.D. Pa. 1987)(followed)
- Pappas v. Asbel, 564 Pa. 407, 768 A.2d 1089 (2001)(followed)
- Hooven v. Exxon Mobil Corp., 465 F.3d 566 (3d Cir. 2006)(distinguished)
- Chiropractic Nutritional Associates, Inc. v. Empire Blue Cross & Blue Shield, 447 Pa. Super. 436, 669 A.2d 975 (1995)(followed)
- Kemmerer v. ICI Americas Inc., 70 F.3d 281 (3d Cir. 1995)(quoted)
- Aetna Health Inc. v. Davila, 542 U.S. 200, 124 S. Ct. 2488, 159 L. Ed. 2d 312 (2004)(quoted)
- Reichelt v. Emhart Corp., 921 F.2d 425 (2d Cir. 1990)(quoted)
- Carr v. First Nationwide Bank, 816 F. Supp. 1476 (N.D. Cal. 1993)(quoted)
Cited In (0)
No citing cases on record yet.
Court Document
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