Peck v. SELEX Systems Integration
United States District Court for the District of Columbia
2016 WL 1225650, 172 F. Supp. 3d 171 (2016)

- Written by Craig Scheer, JD
Facts
Ronald Peck (plaintiff) was an at-will employee of SELEX Systems Integration, Inc. (Selex) (defendant) and a participant in Selex’s Key Employee Deferred Compensation Plan (the plan). On August 23, 2012, following a negative review of Peck’s performance by Selex’s CEO, Peck was reassigned to a new position that required him to relocate. After Peck objected to the reassignment, he received a letter dated September 14, 2012, from the CEO stating that Peck’s refusal to accept the new position was cause for termination of his employment and that he had two weeks to reconsider. Peck did not change his mind, and Selex terminated Peck’s employment for cause effective September 30, 2012. By its terms, the plan precluded an employee terminated for cause from receiving benefits under the plan. The plan’s definition of cause included an intentional refusal to perform the material duties of one’s employment, and the plan’s administrative committee (the committee) had broad discretion to interpret the plan. On April 5, 2013, Peck submitted a claim for benefits under the plan, which was denied by the committee, with Selex’s CEO acting for the committee. On July 11, 2013, Peck appealed to the committee to reconsider its prior decision, which the committee upheld. Peck later sued Selex for his plan benefits pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), contending that he was wrongfully denied his benefits because he was terminated without cause. Peck argued that his unwillingness to accept his new position could not be construed as an intentional refusal to perform the material duties of his employment because he was never employed in that position. Peck also argued that because Selex’s CEO initially determined that Peck’s refusal to accept the reassignment was cause for termination, the CEO should have abstained from voting on the review of that determination as a member of the committee. Selex and Peck both filed motions for summary judgment.
Rule of Law
Issue
Holding and Reasoning (Leon, J.)
What to do next…
Here's why 815,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.