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Curtis v. Alcoa Inc.

October 17, 2007

CHARLES CURTIS, ET AL., PLAINTIFFS,
v.
ALCOA INC., INDIVIDUALLY AND AS FIDUCIARY OF THE EMPLOYEES' GROUP BENEFITS PLAN OF ALCOA INC., PLAN II, DEFENDANTS.



The opinion of the court was delivered by: Thomas W. Phillips United States District Judge

(Phillips/Shirley)

MEMORANDUM OPINION

This is a class action brought pursuant to the Labor-Management Relations Act of 1947 (LMRA), 29 U.S.C. §§ 141-187 (2006) and the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. §§ 1001-1461 (2006) by a group of Alcoa retirees and/or their surviving spouses seeking fully funded lifetime retiree healthcare benefits. In essence, the class consists of retirees who retired between June 1, 1993 and June 30, 2006, their eligible spouses and dependants, and surviving spouses of such retirees and of active vested employees who died while still employed by Alcoa.*fn1 Currently pending is the plaintiffs' motion for a preliminary injunction pursuant to Rule 65, Fed. R. Civ. P. [Court File #117] and plaintiffs' demand for a jury trial [Court File #43 at p.25].

Because of the complexity of the issues involved and the sheer volume of documents produced (including Collective Bargaining Agreements (CBAs), Summary Plan Descriptions (SPDs), and other attached documentation for the years 1977 through 2006), the court has prepared this memorandum to aid the parties in efficiently preparing the matter for trial. This memorandum addresses three issues:

(1) Whether, pursuant to the Seventh Amendment, plaintiffs are entitled to a jury trial;

(2) Whether, pursuant to Rule 65(a)(2), the hearing of plaintiffs' motion for a preliminary injunction should be consolidated with the hearing of the trial on the merits;

(3) Whether, in light of UAW v. Yard-Man, Inc., 716 F.2d 1476 (6th Cir. 1983), and its progeny, extrinsic evidence will be necessary to determine the intent of the parties to the relevant CBAs.

For the reasons that follow the court concludes the plaintiffs are not entitled to a jury trial, the preliminary injunction hearing will be consolidated with the trial on the merits, and the admission of extrinsic evidence will be necessary to determine the intent of the parties to the relevant CBAs.

I. Entitlement to a Jury

The relevant statutes in this case, the LMRA and ERISA, are silent with regard to a right to jury trial. Therefore, if a right to a jury trial exists, it must be guaranteed by the Seventh Amendment. The Seventh Amendment states, "In suits at common law ... the right to trial by jury shall be preserved ...." U.S. Const., amend. VII, cl. 1. Though the language refers to the common law, the Seventh Amendment extends to statutory claims. Curtis v. Loether, 415 U.S. 189, 194 (1974) ("The Seventh Amendment does apply to actions enforcing statutory rights ... ."). In a statutory claim, there is a right to jury trial "if the statute creates legal rights and remedies, enforceable in an action for damages in the ordinary courts of law." Id. (emphasis added).

To determine whether the relevant statute creates legal rights and remedies such that the Seventh Amendment is applicable, the court employs a two-part test: "First, we compare the statutory action to 18th-century actions brought in the courts of England prior to the merger of courts of law and equity. Second, we examine the remedy sought and determine whether it is legal or equitable in nature." Tull v. United States, 481 U.S. 412, 417-18 (1987) (citations omitted). The latter inquiry "is the more important in our analysis." Chauffeurs, Teamsters, & Helpers Local No. 391 v. Terry, 494 U.S. 558, 565 (1990).

The Sixth Circuit has, on several occasions, applied this test and concluded that the Seventh Amendment does not guarantee the right to a jury trial in claims brought under the relevant sections of ERISA and the LMRA. See, e.g., Wilkins v. Baptist Healthcare Sys., 150 F.3d 609, 616 (6th Cir. 1998) (no jury trial for ERISA denial of benefits action); Bittinger v. Tecumseh Prods. Co., 123 F.3d 877, 882-83 (6th Cir. 1997) (no jury trial for § 301 of the LMRA and § 502(a)(1)(B) of ERISA); Golden v. Kelsey-Hayes Co., 73 F.3d 648 (6th Cir. 1996)(no jury trial for LMRA § 301 claim); Bair v. Gen. Motors Corp., 895 F.2d 1094 (6th Cir. 1990) (quoting Daniel v. Eaton Corp., 839 F.2d 263, 268 (6th Cir. 1988) (no jury trial for recovery of benefits under ERISA § 502).

Particularly instructive here are the Golden and Bittinger cases. In Golden, plaintiff class sought relief under § 301 of the LMRA, including a declaratory judgment, preliminary and permanent injunctive relief, and damages for the benefits denied to the class. Golden, 73 F.3d at 660. Applying the test dictated by Tull and its progeny, the Sixth Circuit determined that while the action was "comparable to a breach of contract claim -- a legal issue," id. at 659 (quoting Terry, 494 U.S. at 570, 570 n. 7), under the second, more important prong of the inquiry, the relief sought was equitable, thereby defeating a right to jury trial. Id. at 660-61.

Though monetary damages are often legal in nature, the court further concluded that any monetary relief sought was equitable, as it was " 'incidental to or intertwined with equitable relief.'" Id. at 661 (quoting Terry, 494 U.S. at 571). Though the Supreme Court has ruled that any legal issues, even though merely incidental to equitable issues, must be heard by a jury, id.; see Tull, 481 U.S. at 425 (quoting Curtis, 415 U.S. at 196 n.11), the Sixth Circuit held that "[a] court does not err in denying a jury trial where the monetary award sought is incidental to, or intertwined with, equitable relief." Golden, 73 F.3d at 661. According to the court, the monetary damages sought were "exactly the type of monetary relief that courts, and the Restatement, envision as equitable relief; they are incidental to the grant of equitable relief, yet are ...


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