The employee alleged that Pactiv terminated him in breach of its fiduciary duty to him under the terms of the health plan administered by the employer and/or in retaliation for his assertion of a workers’ compensation claim based on an on-the-job accident injuring his hand, wrist, and forearm.
The Court held that the termination did not violate any fiduciary duty under ERISA. However, the record contained sufficient evidence regarding Brooks' retaliation claim because Pactiv's demand just prior to firing Brooks that he verify his ability to perform his job duties as condition of his continued employment could have been motivated by Pactiv's desire to undermine Brooks' pending workers’ compensation claim in which he alleged total disability. The Court also noted that termination took place just after Pactiv began receiving Brooks' extensive medical bills that were being paid either through workers’ compensation proceeding or through company’s health insurance.