Williams v. The NFL Player Supplemental Disability Plan

Background

Delvin Williams, a former National Football League player, sued the Bert Bell/Pete Rozelle NFL Player Retirement Plan, the Retirement Board of that Plan, and the NFL Player Supplemental Disability Plan. He sought additional total and permanent disability benefits.

Williams had previously been awarded Football Degenerative benefits. In 2018, he asked the Board to reclassify those benefits as Active Football benefits. The Board denied the request, concluding that the record did not show that Williams became totally and permanently disabled within the period required by the Plan’s “shortly after” standard.

The Plan defines Active Football benefits as requiring a disability arising from League football activities while the player is active and causing total and permanent disability shortly after the disability arises. The Plan defines “shortly after” as no later than six months after the disability first arises and provides that the standard is not met if total and permanent disability occurs more than 12 months after the disability first arises. The Plan gives the Board discretion to interpret the Plan and decide benefit claims.

Prior Related Proceeding

In an earlier round of this dispute, Williams challenged the denial of an earlier effective date for his disability benefits. The Ninth Circuit held that substantial evidence supported the Board’s conclusion that Williams was not totally and permanently disabled before July 1995. The evidence included medical records from 1983 and 1984 and Williams’s employment and earnings history.

Defendants’ Motion

Defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. Williams filed his opposition one day late, without identifying good cause for the delay. The court nevertheless considered the opposition.

Failure to State a Claim

The court applied abuse-of-discretion review because the Plan gave the Board discretionary authority. Under that standard, the question was whether Williams alleged enough facts to show that the Board abused its discretion in denying reclassification.

The court concluded that the complaint did not do so. It contained general statements that Defendants failed to pay benefits owed under the Plan and applicable law, but it did not explain why Williams was entitled to Active Football benefits or how the Board’s decision violated the Plan or the law. The court therefore granted Defendants’ motion to dismiss on the ground that the complaint failed to state a claim under Rule 12(b)(6).

Issue Preclusion

The court also held that issue preclusion barred the lawsuit. Issue preclusion prevents a party from relitigating an issue that was identical to an issue in an earlier proceeding, actually litigated and decided there, fully and fairly litigated, and necessary to the earlier decision.

The court determined that Williams’s current claim required him to show that the Board abused its discretion by finding that he was not totally and permanently disabled shortly after his retirement. The court found that this was the same issue decided in the earlier proceeding. The Ninth Circuit had previously held that medical evidence and Williams’s work history supported the Board’s determination that he was not totally and permanently disabled before July 1995.

The court rejected Williams’s argument that issue preclusion did not apply because the Ninth Circuit had relied on the administrative record available at that time. The court found that the current complaint relied on the same medical records and employment information considered previously. It concluded that the question of whether the Board abused its discretion in finding that Williams was not totally and permanently disabled before July 1995 had already been litigated and decided.

Disposition

The court held that leave to amend would be futile because issue preclusion barred Williams from relitigating the relevant issue. It also stated that allowing amendment would unduly prejudice Defendants by requiring them to relitigate a claim already rejected by the Ninth Circuit.

The court granted Defendants’ motion to dismiss the complaint with prejudice.