Martinez v The Plumbers & Pipefitters National Pension Plan

Martinez sought to change pension benefits received during a period of health related retirement to disability payments. Plan refused. The district court granted summary judgment to Plan. The panel affirmed. It held that under the unambiguous terms of the plan, Martinez is only entitled to one benefit, he took early retirement which was suspended when he went back to work and the reinstatement was not a new application merely a restart of his earlier benefit. The panel also rejected a claim of equitable estoppel as Plan made no false statements and any reliance by Martinez was unreasonable.