Phelps v. Field Real Estate Co.

John Phelps (plaintiff) was hired as a manager of a commercial real-estate division for Field Real Estate Company (Field) in February 1985. Phelps reported to W. Douglas Poole, the chairman of the board and the chief executive officer of Field. Phelps generally received positive performance reviews over the next few years, but consistently failed to meet Poole’s sales expectations. In 1986, Phelps was diagnosed with the virus that causes acquired immunodeficiency syndrome (AIDS). In March 1988, Phelps’s condition was anonymously disclosed to Poole. Although initially concerned, Poole was satisfied after receiving a doctor’s note that Phelps’s condition would not interfere with Phelps’s ability to work. In the summer of 1988, the real-estate commercial division had particularly poor sales. Poole decided to reorganize Field and placed an advertisement for a real-estate commercial-division manager in an apparent effort to prompt Phelps to resign. In August 1989, over 14 months after Phelps disclosed that he had the AIDS virus, Field discharged Phelps, in part due to poor performance and in part because of the reorganization. Phelps sued Field, claiming that the discharge violated the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. § 1140, because the discharge interfered with Phelps’s receipt of benefits under ERISA. The district court ruled that Phelps had failed to establish that Field had the requisite intent under ERISA and ruled in favor of Field. Phelps appealed.