TEAMSTERS LOCAL UNION NO 340 v. EATON et al
Filing
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ORDER adopting Report and Recommended Decision re 29 Report and Recommendations; granting 25 Motion for Judgment on the Record for Judicial Review (ERISA); denying 26 Motion for Judgment on the Record for Judicial Review (ERISA) By JUDGE JON D. LEVY. (jgw)
UNITED STATES DISTRICT COURT
DISTRICT OF MAINE
TEAMSTERS LOCAL UNION NO. 340,
Plaintiff,
v.
KENNETH L. EATON and
CARL GUIGNARD,
Defendants .
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) Case No. 2:13-cv-264-JDL
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ORDER ADOPTING THE RECOMMENDED DECISION OF THE
MAGISTRATE JUDGE
I. INTRODUCTION AND BACKGROUND
This case is before the court on plaintiff Teamsters Local Union No. 340’s
(“Teamsters”) complaint brought under the Employee Retirement Income Security
Act of 1974 (“ERISA”), 29 U.S.C.A. § 1001 et seq. (2013). ECF No. 1. The Teamsters
seek a declaratory judgment that they may properly modify the retiree health
insurance benefits of certain former employees, including defendants Kenneth L.
Eaton (“Eaton”) and Carl Guignard (“Guignard”). Id. After the parties filed crossmotions for judgment on the administrative record, ECF No. 25; ECF No. 26,
Magistrate Judge John H. Rich, III issued a Recommended Decision granting the
Teamsters’ motion and denying Eaton and Guignard’s motion. ECF No. 29. Eaton
and Guignard object. ECF No. 32. For the reasons that follow, I adopt the Magistrate
Judge’s Recommended Decision.
II. DISCUSSION
Eaton and Guignard object to the Recommended Decision on the ground that
the Magistrate Judge “failed to address their detrimental reliance argument[.]” ECF
No. 32 at 2. In support, they point to an excerpt in their Motion for Judgment on the
Administrative Record in which they argue that they “relied on the representations .
. . regarding their retiree health insurance coverage[.]” Id.; ECF No. 26 at 9. This
passage appears in the motion under the heading, “Defendants’ Contractual Right to
Receive Health Insurance Coverage Under Local 340’s Retiree Health and Welfare
Plan is Vested and not Subject to Reduction or Elimination.” ECF No. 26 at 7. Eaton
and Guignard’s motion contended that their contractual retirement benefits had
vested under ERISA. Id. The motion, along with the other materials before the
Magistrate Judge, otherwise made no mention of detrimental reliance or, more
generally, the principle of promissory estoppel. See ECF No. 7; ECF No. 16; ECF No.
19; ECF No. 26; ECF No. 28. See also Harvey v. Dow, 2008 ME 192, ¶ 11, 962 A.2d
322 (noting that promissory estoppel claim requires showing a promise, reliance on
that promise, and injustice if promise is not enforced).
A party is entitled to de novo review of arguments that were properly raised
before the Magistrate Judge.
Paterson-Leitch Co., Inc. v. Massachusetts Mun.
Wholesale Elec. Co., 840 F.2d 985, 990-91 (1st Cir. 1988) (“[A]n unsuccessful party is
not entitled as of right to de novo review . . . of an argument never seasonably raised
before the magistrate.”); see also Vining v. Astrue, 720 F. Supp. 2d 126, 128 (D. Me.
2010) (“[T]he law is clear in this Circuit that failure to raise an argument before the
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Magistrate Judge waives it before the District Court.”).
To properly raise an
argument, a party must do more than “seed[ ] the record with mysterious references.”
Paterson-Leitch, 840 F.2d at 990. Arguments must be spelled out “squarely and
distinctly,” and a single sentence reference that fails to cite authority may not suffice.
Id.
The
passing
reference
in
defendants’
motion to
their
reliance
on
representations regarding their benefits, made as part of their argument that they
had vested contractual rights, is a far cry from “squarely and distinctly” raising the
quasi-contractual theory of detrimental reliance or promissory estoppel as a basis for
relief. Because detrimental reliance was not presented to the Magistrate Judge for
consideration, Eaton and Guignard have failed to preserve their right to raise the
issue as part of my de novo review.
Detrimental reliance being the only issue cited by Eaton and Guignard in their
objection to the Recommended Decision, see ECF No. 32, there are no other issues
presented for de novo review. See Keating v. Sec’y of Health and Human Servs., 848
F.2d 271, 275 (1st Cir. 1988) (“[O]nly those issues fairly raised by the objections to
the magistrate’s report are subject to review in the district court and those not
preserved by such objection are precluded on appeal.”).
III. CONCLUSION
It is ORDERED that the Recommended Decision of the Magistrate Judge is
hereby ADOPTED. Plaintiff’s Motion for Judgment on the Administrative Record is
GRANTED; defendants’ Motion for Judgment on the Administrative Record is
DENIED. Judgment for plaintiff shall issue separately.
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SO ORDERED.
Dated: January 30, 2015
/s/ Jon D. Levy
U.S. District Judge
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