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Felix v. Lucent Technologies, Inc.
United States Court of Appeals for the Tenth Circuit
387 F.3d 1146 (2004)
In 2001 Lucent Technologies, Inc. (Lucent) (defendant) began selling off its manufacturing plants. To make its business more attractive to potential buyers, Lucent wanted to reduce its number of long-term senior employees. To meet its goals, Lucent offered its senior employees an increased retirement benefit and an $11,000 bonus if they would retire by June 30, 2001. The offer was categorized by Lucent as a one-time offer that would be forfeited after June 30. Aaron Felix and other senior employees (collectively, the former employees) (plaintiffs) took the offer and retired on June 30, 2001. On October 1, 2001, Lucent offered its remaining senior employees the same retirement package that it offered the former employees, plus an additional $15,000. The former employees sued Lucent in state court, arguing that Lucent committed fraud by intentionally misrepresenting its retirement offer to the former employees and inducing the former employees to retire early to their detriment. Lucent moved to remove the case to federal court. In support of its motion, Lucent argued that the former employees’ claims were preempted by the Employment Retirement Income Security Act (ERISA), a federal law that governed employee pension plans. The district court granted Lucent’s motion and removed the case to federal court. The former employees appealed.
Rule of Law
Holding and Reasoning (Ebel, J.)
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