Stephen Richards v. Centric Manufacturing Solutions, Inc.

Summary

The United States District Court for the Eastern District of Wisconsin denied Centric Manufacturing Solutions, Inc.'s motion for judgment on the pleadings in an ERISA action brought by Stephen Richards. The court held that whether Centric's delayed payment of accrued paid time off constituted a material breach of the severance and release agreement, and whether Richards could rescind the agreement, could not be resolved at the pleading stage. The court also denied Richards's motion to file an additional declaration and directed the clerk to schedule a Rule 16 conference.

Holdings

1. Judgment on the pleadings was premature because the pleadings did not conclusively establish that the release barred Richards's ERISA claims. The alleged breach, its materiality, whether time was of the essence, and the adequacy of a damages remedy presented issues that could not be resolved against Richards at the pleading stage.
2. The court may decide a Rule 12(c) motion based on the pleadings and documents properly considered part of the pleadings, but it did not rely on either declaration submitted in connection with the motion.
3. Richards's motion for leave to file an additional declaration was denied because declarations were not properly considered in deciding the Rule 12(c) motion.

Questions Presented

1. Whether Centric was entitled to judgment on the pleadings on the ground that the severance and release agreement barred Richards's ERISA claims.
2. Whether the pleadings conclusively established that Centric's failure to pay PTO in a timely manner was not a material breach and could not support rescission of the agreement.
3. Whether the court could consider declarations submitted in connection with the Rule 12(c) motion.
4. Whether Richards should be permitted to file an additional declaration after Centric's reply.

Disposition

other