Peck v. SELEX Systems Integration

2016 WL 1225650, 172 F. Supp. 3d 171 (2016)

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Peck v. SELEX Systems Integration

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

CS

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.)

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