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← 201 F. Supp. 2d 1012 - Eckelkamp v. Beste

201 F. Supp. 2d 1012 - Eckelkamp v. Beste’s Empirical Analysis

2002

Citation profile

10
cited by 10 later decisions
April 2019
most recently cited

3 federal appellate · 1 district ·

Relationships

Applies 29 U.S.C. § 1002 (§ 3 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1103 (§ 403 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1104 (§ 404 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1105 (§ 405 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1108 (§ 408 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1109 (§ 409 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1140 (§ 510 of the Employee Retirement Income Security Act of 1974)

Relies on Anderson v. Liberty Lobby, Inc. · Celotex Corporation v. Catrett H · Matsushita Electric Industrial Co., Ltd. v. Zenith Radio Corporation · Poller v. Columbia Broadcasting System, Inc. · LOCKHEED CORP. Et Al. v. SPINK

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““Setting compensation levels is a business decision or judgment made in connection with the on-going operation of a business.” See Eckelkamp v. Beste, 201 F.Supp.2d 1012, 1023 (E.D.Mo.2002), aff'd, 315 F.3d 863 (8th Cir.2002). Consequently, ERISA does not govern Blue Cross’s business decision about how to classify an employee for payroll and FLSA purposes. Nor do Plaintiffs dispute this. (Pis.’ Opp’n Mem. at 27-28.) Instead, they make the very fine distinction that Blue Cross, as plan administrator, has a fiduciary duty to double-check this business decision and evaluate whether employees had some legal claim to additional compensation. (Id. at 22, 27-30.) But no such duty exists: An employer’s discretion in determining salaries is a business judgment which does not involve the administration of an ERISA plan or the investment of an ERISA plan’s assets. Such a decision may ultimately affect a plan indirectly but it does not implicate fiduciary concerns regarding plan administration or assets. Business decisions can still be made for business reasons, notwithstanding their collateral effect on prospective, contingent employee benefits. Eckelkamp, 201 F.Supp.2d at 1023 ....”
    2 later decisions quote this exact passage
  2. “credible evidence indicates that [the individual defendants] are paid approximately 56% above the median.”
    1 later decision quote this exact passage

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.