Kramer v. American Elec. Power Exec. Severance Plan, No. 24-3174, __ F.4th __, 2025 WL 444923 (6th Cir. Feb. 10, 2025) (Before Circuit Judges Cole, Mathis, and Bloomekatz)

Your ERISA Watch is short-staffed this week, so we won’t be providing our usual comprehensive coverage of all the week’s ERISA-related decisions. Instead, we are highlighting

Carlson v. Northrop Grumman Severance Plan, No. 22-1764, __ F. 4th __, 2023 WL 3299703 (7th Cir. May. 8, 2023) (Before Circuit Judges Easterbrook, Hamilton, and Lee)

In this certified class action, former Northrop Grumman employees filed suit against the Northrop Grumman Severance Plan, contending that its refusal to pay severance benefits to

This week’s notable decision is Castellon-Vogel v. International Paper Company, __F.App’x__, 2020 WL 5891679 (6th Cir. Oct. 5, 2020). Martha Castellon-Vogel (Vogel) worked as an engineer for International Paper Company (IPC). The company’s ERISA welfare benefit plan provided that Vogel could receive a severance package at the end of her employment if, among other conditions, she “sign[ed] a termination agreement acceptable to the Company.” After her job was eliminated, Vogel signed such a “Termination Agreement,” which included a broad General Release. That provision released IPC of liability for all employment-related claims arising during her tenure. She then received fifty-four weeks’ pay, in accordance with the Plan’s terms. Despite cashing the check, Vogel sued IPC. She argued on appeal that the Plan’s terms were illusory and that the General Release in the Termination Agreement was unenforceable for lack of consideration.
Continue Reading Sixth Circuit Affirms Dismissal of Claims Challenging Severance Plan’s General Release Requirement