Royal v. National Football League Management Council

Background

Andre Royal developed seizures while playing football for the National Football League and retired from the Indianapolis Colts in 2000. He applied for disability benefits under the 1995 Bert Bell/Pete Rozelle NFL Player Retirement Plan. The plan administrator classified him as totally and permanently disabled in the “football degenerative” category, and he began receiving disability benefits in 2001.

In 2015, Royal sought reclassification into the “active football” category. The Retirement Board denied that request and denied his appeal. Royal did not seek judicial review of either his original benefits decision or the reclassification decisions.

Royal filed this action in 2019. After amending his complaint, he pursued claims against the Retirement Board and several Board members based primarily on an alleged failure to provide him with a summary plan description, or SPD, that was understandable to an average plan participant. He also asserted a breach-of-fiduciary-duty claim under the Employee Retirement Income Security Act, or ERISA. Royal voluntarily dismissed his claims against the National Football League Players Association and the National Football League Management Council.

Standing

The Board argued that Royal lacked Article III standing because receiving a proper SPD would not have changed the benefits he received. The court rejected that argument. It held that ERISA gives plan participants an independently enforceable right to receive a compliant SPD, and that Royal had a concrete interest in receiving information about his rights under the plan even if the information would not necessarily have produced higher benefits.

Statute of limitations

The court held that Royal’s disclosure-related claims were time-barred. For the fiduciary-duty claim, ERISA generally requires suit within the earlier of six years after the violation or three years after the plaintiff had actual knowledge of it. For the SPD claim, the court followed decisions applying New York’s three-year limitations period for statutory violations.

Royal alleged that he did not receive the SPD when he applied for benefits in 2000 and knew of that failure at the time. The court therefore concluded that the three-year period expired in 2003. It also held that Royal had not plausibly alleged fraud or concealment that would extend the limitations period. Even under the longer period applicable to fraud, the court said the claim would have expired in 2006.

The court rejected Royal’s argument that the limitations period began when he learned, after his 2015 reclassification request, how the Board interpreted the plan’s terms concerning “clear and convincing evidence” and “changed circumstances.” The court concluded that his alleged injury arose from the failure to provide the SPD in 2000, not from his later discovery of the Board’s interpretation.

Other claims and amendment

Royal did not defend his remaining claims in his opposition to the motion to dismiss. The court found that his claim seeking a declaration that a 2017 plan amendment was void failed to satisfy Federal Rule of Civil Procedure 8 because it was unintelligible and lacked supporting explanation. It found that his claim seeking a declaration that the plan’s limitations period was void was untimely and possibly not independently actionable. The court dismissed those claims as well.

The court denied leave to amend again because any further amendment would be futile: the claims were plainly time-barred.

Disposition

Judge Alison J. Nathan granted the Board’s motion to dismiss and dismissed all claims with prejudice. The clerk was directed to close the case.