November 2, 2018

Pension plan managers vested with exclusive authority to determine a member's retirement benefits precludes judicial review of its calculation of Plan benefits


Pension plan managers vested with exclusive authority to determine a member's retirement benefits precludes judicial review of its calculation of Plan benefits
Hughey v Metropolitan Transp. Auth., 2018 NY Slip Op 02129, Appellate Division, First Department

Plaintiff in this action retired from his position with the Long Island Rail Road, an MTA subsidiary, at age 63.49. Plaintiff, as a commuter rail employee, was also eligible to  receive Tier II pension benefits after the requisite years of service under the Railroad Retirement Act. In addition, MTA employees receive pension benefits from the MTA Pension Plan.

Article 3.07(a)(ii) of the MTA Pension Plan, provide for an "offset" that reduced the amount of benefits payable under the Plan by the benefits "which would be payable to the Member involved at age 62 under Tier II. "Plaintiff, however, was still in service at age 62 and did not retired from MTA at age 63.49. Accordingly, the amount of the offset was determined by the MTA's Board of Managers on the basis of Plaintiff's actual age at the effective date of his retirement, 63.49 years of age.

Plaintiff sought a review of the Board's determination basing his pension benefits on his actual age at retirement, 63.49 years rather than determining his pension benefits to be that which would have been payable had he actually retired at age 62, a difference of $160.83 per month.

The Board denied Plaintiff's appeal, which determination was affirmed by the Appellate Division. 

The court explained that "Article 6.02 of the Plan conferred on its Board of Managers" sole and absolute discretionary authority to interpret the Plan and decide any dispute and all matters arising in connection with the operation or administration of the Plan, as well as to decide questions, including legal and factual questions, relating to the calculation and payment of benefits under the Plan.

The decision is posted on the Internet at:


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