AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Plaintiff, an employee of the Defendant for over ten years, was diagnosed with Emery-Dreyfus Muscular Dystrophy during his employment. He applied for long-term disability (LTD) benefits, as outlined in the employee benefits handbook provided by the Defendant. The handbook stated that LTD benefits were equal to 60% of the employee's base salary up to $5,000 per month, at no cost to the employee. However, the LTD insurance policy included a provision that benefits would be offset by any deductible sources of income, including federal social security disability compensation. The Plaintiff, having only read the portion of the handbook regarding the 60% base salary benefit, was under the impression that he would receive this amount without offsets. After applying for and receiving social security disability benefits, the Plaintiff learned that his LTD benefits would be reduced by the amount received from social security, leading him to file a complaint for breach of contract or, alternatively, promissory estoppel against the Defendant.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff: Argued that the employee handbook created an unambiguous promise that he would receive LTD benefits equal to 60% of his base salary without an offset for social security disability benefits received.
• Defendant: Contended that the handbook was a summary of benefits that expressly incorporated the more specific terms of the insurance policy, which included the offset provision for deductible sources of income like social security disability benefits.

Legal Issues

• Whether the district court erred in granting summary judgment in favor of the Defendant on the Plaintiff's breach of contract claim based on the provisions contained in an employee benefits handbook.

Disposition

• The Court of Appeals affirmed the district court's decision to grant summary judgment in favor of the Defendant.

Reasons

• The Court, with Judges Michael E. Vigil, Michael D. Bustamante, and Roderick T. Kennedy concurring, held that assuming the employee handbook created a contract, its unambiguous terms, when read as a whole, did not support the Plaintiff's claim. The handbook contained a disclaimer stating that in cases of discrepancy, the provisions of the policy and/or plan document would govern. The LTD insurance policy clearly stated that the benefits would be offset by deductible sources of income, including social security disability benefits. The Court found that the Plaintiff's selective reading of the handbook did not create a material issue of fact under the principles established in previous case law, such as DeArmond and Crow. The Court emphasized the importance of reading and understanding the entire contract, including disclaimers and referenced documents, to ascertain the terms of an agreement.