Hall v. National Gypsum Co.

                       United States Court of Appeals,

                                 Fifth Circuit.

                                  No. 95-31107.

                       Willie HALL, Plaintiff-Appellee,

                                         v.

 NATIONAL GYPSUM CO., as Plan Administrator of the Pension Plan
for Hourly-Paid Employees of the Gold Bond Products Division of
National Gypsum Co., Located in New Orleans, La., # 667, Defendant-
Appellant.

                                  Feb. 6, 1997.

Appeal from the United States District Court for the Eastern
District of Louisiana.

Before REYNALDO G. GARZA, JOLLY and DeMOSS, Circuit Judges.

     REYNALDO G. GARZA, Circuit Judge:

     In a case presenting an unusual factual context, the National

Gypsum       Company   appeals   from    a    judgment   ordering      it,   as   the

administrator of a pension plan, to pay disability benefits to an

alleged plan participant and former employee, Willie Hall.1 For the

reasons discussed below, we vacate the district court's judgment

and remand the case with instructions.

                                         I.

     Willie Hall served as an employee at a building-products

manufacturing      plant   in    New    Orleans   from   July    19,   1965   until

November 29, 1981, when he underwent a below-the-knee amputation of

his left leg due to complications from diabetes.                When he began his

employment, the plant was owned and operated by National Gypsum,


         1
       The benefits are now owing to Hall's wife, as Hall died
during the course of this litigation.

                                          1
which established the Retirement Plan for Hourly-Paid Employees of

the Gold Bond Products Division of National Gypsum ("the Plan").

The Plan included provisions for retirement pension benefits as

well as disability pension benefits.          Under the terms of the Plan,

Hall's pension rights had vested as of March 10, 1981.              On March

11, 1981, National Gypsum sold the plant to International Building

Products, Inc. ("IBP").

     National Gypsum assured its employees that those who continued

to work at the plant were not considered terminated for purposes of

the Plan. IBP did not have a plan of its own, so as part of the

sale,       National   Gypsum   apparently   maintained   control   over   the

pension plan for the employees at the plant.2                The collective

bargaining agreement in place between IBP and Hall's union, Local

No. 667 of the Laborers International Union, stated:

          For vesting purposes, under any pension plan adopted by
     International Building Products, Inc., employees formerly
     employed by National Gypsum Company who have not elected
     retirement under the National Gypsum Company pension plan
     shall be given credit for years of employment with National
     Gypsum Company. In addition, International Building Products,
     Inc. has arranged for its continuing employees to receive
     credit for vesting purposes under the National Gypsum Company
     pension plan for years of employment with International
     Building Products, Inc., provided however that the full
     responsibility for the payment of any benefits under any
     National Gypsum Company pension plan shall be solely that of
     National Gypsum Company.

The Plan provided for disability benefits to those who met the

required term of service and "who shall have become, through some

unavoidable cause, permanently incapacitated, and who shall at such


        2
      The district court's resolution of this disputed fact is an
issue of this appeal. See Part II.E of this opinion.

                                       2
time be in the employ of the Company."

       On September 28, 1982, Hall submitted a claim for disability

benefits to IBP premised on his amputation. IBP referred the claim

to National Gypsum which refused to pay on the claim because Hall's

doctor had not declared Hall "totally and permanently disabled" as

required by the language of the Plan. When Hall subsequently

provided a statement from his doctor stating that he was in fact so

disabled, National Gypsum again refused to pay, this time stating

that his disability occurred after his termination as an employee

of National Gypsum, thereby making him ineligible under the Plan.

Correspondence between National Gypsum and Hall continued, but

National Gypsum refused to pay Hall's disability benefits.                          When

Hall contacted the company that coordinated the annuity payments

made to recipients of Plan benefits, Canada Life Assurance, he was

told that it exercised no control over who received benefits under

the Plan. All of those decisions, Canada Life stated, were made by

National Gypsum.

       On October 28, 1990, National Gypsum filed for bankruptcy

protection       under   Chapter    11   in     the   Bankruptcy     Court    for    the

Northern District of Texas. On March 9, 1993, that court confirmed

a    plan   of   reorganization      that       discharged    all    claims   against

National Gypsum arising prior to the confirmation or resulting from

conduct occurring prior to the confirmation, excepting certain

asbestos-related claims.           The assets of the Plan were not included

in    National     Gypsum's   bankruptcy         estate,     but    were   apparently

transferred to Morgan Guaranty Trust for credit to the account of


                                            3
Canada Life Assurance Company, "in order to purchase annuities for

all benefits accrued as of March 10, 1981."                   Hall did not file any

claim with the bankruptcy court.

     He did, however, sue National Gypsum, as the administrator of

the Plan, in federal district court in New Orleans on May 7, 1993.

His complaint alleged that his claim for disability benefits was

wrongfully denied, thereby stating a cause of action under §

502(a)(1)(B)    of   the     Employee      Retirement         Income       Security   Act

(ERISA), 29 U.S.C. § 1132(a)(1)(B).              He did not include the Plan as

a party to the suit although ERISA does provide for this.                              As

discussed below, however, a suit against the Plan would have been

futile because the Plan's administrator, National Gypsum, claims

the Plan no longer exists.           National Gypsum claimed that suit was

barred   because     of    the    running     of   the       applicable      period   of

prescription,      because       Hall   failed     to    exhaust       administrative

remedies under the Plan, and because of the discharge it received

in bankruptcy.       It also stated that Hall was not entitled to

benefits under the Plan because the Plan ceased to exist and

because Hall did not qualify as an "employee" under the Plan.

     The district court denied the parties' motions for summary

judgment and set the case for a bench trial.                     The court and the

parties then decided to forego a trial and the court decided the

case based on "the briefs, stipulations, and depositions already

received in the record."           On January 31, 1995, the court ordered

National   Gypsum's       "Pension      Committee"      to    hold     a    hearing   "to

determine whether plaintiff is totally and permanently disabled and


                                          4
eligible for benefits under the Plan." National Gypsum petitioned

the court for clarification as to what it meant by "Pension

Committee," but the motion was denied.           National Gypsum never held

any hearing on Hall's disability status and Hall moved for entry of

final judgment and for attorney's fees and costs.                The district

court granted his motion, awarding disability pension payments to

Hall in accordance with the terms of the Plan and awarding him

attorney's fees and costs.    National Gypsum appeals.

                                     II.

       Our review of the district court's conclusions of law is

plenary.   We will uphold the district court's findings of fact so

long as they are not clearly erroneous.           This applies to findings

based on oral as well as documentary evidence. Fed.R.Civ.P. 52(a).

When, as is the case here, the evidence relied upon by the district

court in making its findings consists solely of documents in the

record, the burden of establishing clear error is not so great as

where the court engaged in the judging of witness credibility or in

some other way was in a superior vantage point for finding facts.

E.g., Cooper v. Department of the Navy, 594 F.2d 484, 486 (5th

Cir.), cert. denied, 444 U.S. 926, 100 S.Ct. 266, 62 L.Ed.2d 183

(1979).    This does not, however, mean that our review is de novo,

as   National   Gypsum   suggests;         the   language   of    Rule   52(a)

unmistakably sets forth the clear-error standard.

      National Gypsum asserts that the district court erred in

holding that its bankruptcy discharge did not bar Hall's claim,

that the prescription period had not expired, and that Hall's claim


                                      5
was not barred for failing to exhaust administrative remedies.

Moreover, it claims that the district court erred in determining

that Hall was an employee of National Gypsum for purposes of the

Plan and that the district court erred in finding that the Plan did

not terminate on March 10, 1981.             We have engaged in a thorough

review of the record and now address its contentions in turn.

                                        A.

      National Gypsum first contends that Hall should be barred

from recovering any benefits in this suit because he failed to file

a proof of claim in its bankruptcy proceeding.              Bankruptcy Rule

3003(c)(2) provides as follows:

     Any creditor or equity security holder whose claim or interest
     is not scheduled or scheduled as disputed, contingent, or
     unliquidated shall file a proof of claim or interest within
     the time prescribed by subdivision (c)(3) of this rule; any
     creditor who fails to do so shall not be treated as a creditor
     with respect to such claim for the purposes of voting and
     distribution.

The Code defines a "creditor" as an "entity that has a claim

against the debtor that arose at the time of or before the order

for relief concerning the debtor."            11 U.S.C. § 101(10)(A).       It

defines a "claim" as a right to payment or to an equitable remedy

for breach of performance if such breach gives rise to a right to

payment,    whether   or   not   such    right   is   reduced   to   judgment,

liquidated, unliquidated, fixed, contingent, matured, unmatured,

disputed, or undisputed.         11 U.S.C. § 101(5).      Construing Hall's

claim as one for payment of damages from National Gypsum, the claim

would clearly be barred as he would satisfy the definition of a

creditor.     As such, Rule 3003 would have prevented him from


                                        6
recovering out of the bankruptcy estate.

     The     order   of     the   bankruptcy     court    specified      that   "the

discharge herein provided operates as an injunction against the

prosecution    of    the    debtors   ...   of    any    Claim   or    Interest   so

discharged."        In other words, all then-existing claims against

National Gypsum that were not brought to the attention of the

bankruptcy court in the form of a proof of claim were essentially

extinguished upon the court's confirmation of the reorganization

plan. This would include any claim against National Gypsum itself.

     We cannot say, however, that this bars Hall's suit.                   His suit

seeks to collect benefits to which he claims entitlement under the

Plan. As National Gypsum admits, the Plan assets were not part of

its estate in bankruptcy but were segregated from it.                     It stated

that the Plan assets were given to Morgan Guaranty Trust and

credited to the account of Canada Life Assurance for the payment of

annuities to Plan beneficiaries. Moreover, Canada Life stated that

it exercises no control over the assets.                All determinations as to

who receives benefits are made by National Gypsum.                    In requesting

National Gypsum to order an annuity payment, Hall does not collide

with the bankruptcy court's discharge order as money payments will

not come from National Gypsum itself, but from the assets of the

Plan.   In   fact,    had    Hall   filed   a    claim    in   National    Gypsum's

bankruptcy proceeding, the trustee would surely have successfully

argued that the assets of the bankruptcy estate were not subject to

Hall's claim, since he was seeking collection from the assets of

the Plan.


                                        7
      As we stated in Matter of Edgeworth, 993 F.2d 51, 53 (5th

Cir.1993), a discharge in bankruptcy does not extinguish the debt

itself, but merely releases the debtor from personal liability for

the debt.   We there noted that Bankruptcy Code Section 524(e)

specifies that the debt still exists and can be collected from any

other entity that might be liable.      There, the debtor claimed that

a creditor's claim against an insurance policy was barred because

of its discharge in bankruptcy.          We noted, however, that the

crucial inquiry was whether the proceeds of the policy were part of

the bankruptcy estate.     Because we found they were not, the

debtor's general discharge did not bar the creditor's suit for

recovery from the proceeds of the policy.       Id. at 55-56.   Likewise

here, Hall's claim is for assets from the Plan, assets not included

in National Gypsum's bankruptcy estate.         National Gypsum cannot

raise the discharge as a defense to its obligation to pay Hall

benefits he is owed from the Plan assets.

      National Gypsum asserts in its reply brief that Hall cannot

receive this relief because it claims his complaint did not request

this relief.   The complaint asked that National Gypsum, as plan

administrator, pay the benefits.       Even construing this as National

Gypsum does and as the district court apparently did, we cannot

agree with its conclusion that this bars Hall from receiving this

relief.   Federal Rule of Civil Procedure 8(f) requires that all

pleadings be construed to do substantial justice.         "The Federal

Rules reject the approach that pleading is a game of skill in which

one misstep by counsel may be decisive to the outcome and accept


                                   8
the principle that the purpose of a pleading is to facilitate a

proper decision on the merits."             Conley v. Gibson, 355 U.S. 41, 48,

78 S.Ct. 99, 103, 2 L.Ed.2d 80 (1957).                      The record evidence

demonstrates that National Gypsum continued to make eligibility

determinations long after it claims the Plan terminated;                      it is

apparent     that    it   is   the    entity       which    today     controls   the

distribution of funds from the Plan's assets.

     Given     the    confusion      attendant       to    this     unique   factual

situation, much of which only came to light during discovery, we

find no defect in Hall's complaint that bars him from recovering

from the assets of the Plan. We conclude that, in light of National

Gypsum's position throughout this dispute with Hall that the Plan

no   longer    exists,     this      suit       against    National    Gypsum,    as

administrator of the Plan, is the equivalent of an action against

the Plan itself and that Hall is therefore entitled to recover from

the assets of the Plan in accordance with 29 U.S.C. § 1132(d).

Accordingly, we vacate the district court's judgment ordering

National Gypsum to pay Hall's benefits out of its own coffers and

remand with instructions that National Gypsum, as administrator of

the Plan, be ordered to provide benefits to Hall from the Plan's

assets.

                                        B.

     National Gypsum asserts that the district court erred in

determining that Hall's claim was not barred by prescription.                    The

court ruled that the prescription period began to run on February

13, 1984, when Hall received notice that his request for benefits


                                            9
was denied because he was not an active employee at the time of his

disability. Applying Louisiana's ten-year prescriptive period, the

court found Hall's May 7, 1993 suit to be timely.

      ERISA does not set forth a statute of limitations to govern

actions    to   clarify    rights   to      benefits   under   29    U.S.C.   §

1132(a)(1)(B).      We     therefore     look   to   the   state    statute   of

limitations most analogous to the claim being advanced. In Kennedy

v. Electricians Pension Plan, IBEW No. 995, 954 F.2d 1116 (5th

Cir.1992), we held that these claims are governed by Louisiana's

ten-year prescription period, the period applied by the district

court.

         A cause of action under ERISA accrues when a request for

benefits is denied.       E.g., Hogan v. Kraft Foods, 969 F.2d 142, 145

(5th Cir.1992).    National Gypsum asserts that the district court's

finding that Hall's claim was conclusively denied on February 13,

1984 is clearly erroneous.      It states that Hall's claim was denied

at an earlier occasion, either on October 19, 1982 when Hall's

application was returned to him or, at the latest, on February 24

1983 when Hall's attorney inquired into the reasons behind the

administrator's decision.        Hall argues that the return of his

request in October 1982 did not give rise to a cause of action

because the language of the letter did not suggest a conclusive

denial of benefits. Hall contends that a conclusive denial did not

occur until late in 1993 or early in 1994.

      We find that this suit is timely.          The October letter simply

stated that, as Hall had not provided the requisite statement of


                                       10
total   and    permanent       disability,    the   request      could    not     be

considered.     This does not amount to a denial, as proved by a

subsequent letter on March 3, 1983 stating that if Hall provided

this statement, National Gypsum would reconsider the request.

Subsequent correspondence from National Gypsum suggested that Hall

should be making its request to IBP rather than to National Gypsum.

To clarify matters, Hall's attorneys wrote to National Gypsum

informing it that Hall was now totally and permanently disabled and

wanted his benefits.       They also sought clarification, in the form

of documentation, as to which company—National Gypsum or IBP—owed

the disability benefits, since each claimed the other was on the

hook.

      On December 7, 1983, National Gypsum replied that Hall did

have a vested benefit, but because Hall's disability occurred after

his termination as an employee of National Gypsum he was not

entitled to any benefits.         The letter stated that this was due to

a recent administrative decision from National Gypsum's corporate

offices that "no disability benefits will be granted to former

employees who were not disabled while employed" by National Gypsum.

We   find,    contrary    to    the   district   court,    that    this    letter

constituted a conclusive denial of Hall's claim.                 It plainly and

unmistakably     denies    Hall's     claim   and   does   not    try     to    pass

responsibility for Hall's claim to IBP nor does it dispute that

Hall has otherwise made out a proper claim.           Counting this event as

the starting point for prescription purposes, however, does not




                                        11
change the fact that Hall's May 7, 1993 suit was timely.3

                                           C.

           National Gypsum claims that Hall's claim should be barred

because, it states, Hall failed to exhaust available administrative

remedies.       The exhaustion doctrine is applicable to suits brought

under ERISA.       Denton v. First Nat'l Bank of Waco, 765 F.2d 1295

(5th       Cir.1985)   (citing   Amato      v.   Bernard,   618   F.2d    559   (9th

Cir.1980)).       This requirement is not one specifically required by

ERISA, but has been uniformly imposed by the courts in keeping with

Congress' intent in enacting ERISA.                 In the seminal case on the

issue of exhaustion, Amato, the court stated that the purposes of

the    exhaustion      requirement       included   minimizing    the    number   of

frivolous      ERISA   suits,    promoting       the   consistent   treatment     of

benefit claims,        providing     a    nonadversarial    dispute      resolution

process, and decreasing the time and cost of claims settlement.

Amato, 618 F.2d at 567.          In Denton, we additionally noted that the

requirement also serves to provide a clear record of administrative

action if litigation should ensue, and to assure that judicial

review is made under the arbitrary and capricious standard, not de

novo.       765 F.2d at 1300.      We stated this was necessary "to keep

from turning every ERISA action, literally, into a federal case."

       3
     The confusing factual context of this case makes it difficult
to determine the precise date on which the prescriptive period
began to run. This is so because of the absence of an available
administrative appeals process at the time the claim was denied.
In any event, the prescriptive period began no earlier than
December 7, 1983—the date of the first definite denial—and
consequently had not run at the time Hall filed suit. The district
court, therefore, did not commit clear error in finding that the
suit was not barred by prescription.

                                           12
Id. We review the district court's decision to allow suit to

proceed   for   abuse    of   discretion.      E.g.,   Curry   v.   Contract

Fabricators Inc. Profit Sharing Plan, 891 F.2d 842, 846 (11th

Cir.1990).

      The Summary Plan Description (SPD) provided for review of an

adverse determination as follows:

      Upon receipt of denial of claim by you ... an appeal
      requesting further review may be submitted to the Benefits
      Coordinator within 60 days.    You may review any pertinent
      documents held by the Company and you may submit issues and
      comments in writing. Upon receipt for review, the Benefits
      Coordinator will request a review by the Pension Committee
      which will render a decision by no later than 60 days
      following receipt of the request and such decision will be
      submitted to you ... in writing, setting forth all specific
      information on which such decision was based.

Hall does not claim that he formally followed this process to have

his claim reviewed.      National Gypsum claims that this failure bars

the prosecution of this suit.

      The district court found that the repeated letters and phone

calls to National Gypsum were sufficient to trigger the appeals

process, but that National Gypsum did not follow the appropriate

procedures under the Plan for review of a denied claim.                 Hall

requested, per the SPD, the documents upon which National Gypsum

was   relying   for     its   determination,   particularly     the   recent

administrative order from its corporate offices.          He was told, in

response, that this "new" order was really an old policy, merely a

confirmation of what had always been its policy.          He was sent only

what he already had:      language from the Plan. The court noted that

there was neither evidence that a hearing was held to determine

Hall's eligibility for benefits nor that the Pension Committee

                                     13
engaged in any form of review of the denial of his benefits.

Accordingly, it sent the case back into the Plan apparatus and

requested that the Pension Committee review the matter, a perfectly

appropriate request.     See, e.g., Makar v. Health Care Corp. of the

Mid-Atlantic, 872 F.2d 80, 84 (4th Cir.1989) (failure to exhaust

remedied by "remand" to the plan).

     The   reason   no   review   was   had   in   the   first   place   was

inadvertently provided by National Gypsum in a clarification motion

it filed after the district court entered its order.              National

Gypsum asked the court what it meant by "Pension Committee,"

stating, inter alia, that this review body does not exist and, in

fact, has not existed since 1981, long before Hall's dispute over

benefits began.     When the Plan did not act on the court's request

to review its denial of Hall's claim, the court entered judgment in

favor of Hall.

     As we note above, the claim was in fact denied on December 7,

1983. Following the denial, Hall communicated with National Gypsum

twice more to request the documents supporting its decision and to

seek clarification of the decision to deny.              His requests were

unsuccessful.     We believe, like the district court, that these

attempts at nonlitigious resolution of the matter, combined with

the elimination of the Plan's appeal body, National Gypsum's

ever-changing story of why benefits could not be paid, and its

failure to follow the appropriate procedures under the Plan result

in Hall not being barred under the exhaustion requirement.

      As Judge Tjoflat stated for the Eleventh Circuit, "there are


                                   14
occasions when a court is obliged to exercise its jurisdiction and

is guilty of an abuse of discretion if it does not, the most

familiar examples perhaps being when resort to administrative

remedies is futile or the remedy inadequate."    Curry, 891 F.2d at

846 (quoting Amato, 618 F.2d at 568).   The court noted in that case

that none of the purposes served by the exhaustion requirement

would be met by denying the applicant access to the courts.     The

same is true here.   As other courts have recognized, when a plan's

review apparatus has been abolished there is no need for a claimant

to go through the formalities.    E.g., Hutchinson v. Wickes Cos.,

726 F.Supp. 1315, 1321 (N.D.Ga.1989).    We cannot say the district

court's finding that Hall should not be barred under the exhaustion

requirement was error.

                                 D.

      The next issue with which we are confronted is the district

court's finding that Hall constituted an "employee" for purposes of

the Plan, contrary to National Gypsum's contentions.   The parties,

below and on appeal, have spent a great deal of time debating

whether it is the terms of the SPD or those of the Plan itself that

control this definition, with the SPD containing the broader

definition.   We, like the district court, see no need to wade into

the issue of when the terms of an SPD take precedence over those of

the Plan, or vice versa, because even under the stricter definition

National Gypsum's actions demonstrate that it considered Hall, and

all other IBP employees who began work with National Gypsum, to be

employees for purposes of the Plan.


                                 15
       The district court concluded that "the manner in which the

defendant handled plaintiff's claim, as detailed below, and the

obvious intent to continue the Plan for the IBP employees is

conclusive evidence that plaintiff was considered an employee for

purposes of the Plan." It apparently based its finding, at least in

part, on statements made by a National Gypsum representative to IBP

employees that those employees who transferred from National Gypsum

to IBP were not considered terminated for purposes of the Plan.

National Gypsum's Director of Employee Benefits confirmed this

position in a memo in which he stated, "I feel you have expressed

our position fully and nothing more should be said."            We cannot say

the district court's finding is clearly erroneous.                   Because the

Plan    denied   Hall     his    benefits      based    upon   an      erroneous

interpretation   of     who   counted    as   an   employee,   its    denial   of

benefits to Hall was error.              Accordingly, we agree with the

district court that the benefits must be paid.

                                        E.

       The court also found that the Plan did not terminate on March

10, 1981, as National Gypsum claims.           National Gypsum claims this

finding is clearly erroneous.           It argues that the only evidence

before the court on this issue supported a finding that the Plan

was nonexistent.      We disagree.

       The court's memorandum in support of its order relied in part

on the collective bargaining agreement in effect between IBP and

Laborers Local 667. That agreement, as reprinted above in relevant

part, indicated that the Plan was being continued, that National


                                        16
Gypsum was responsible for it, and that former National Gypsum

employees who continued service as employees of IBP would receive

credit for vesting purposes under this Plan. Hall's rights under

the Plan had already vested so this provision does nothing for him

in that sense. This language does, however, support a finding that

the Plan continued to exist.        Moreover, ERISA contains detailed

requirements that must be met before a Plan may be terminated.          See

29 U.S.C. § 1341.     For instance, the Pension Benefit Guaranty

Corporation must be notified before a Plan can be terminated.            29

U.S.C. § 1341(a).   Yet, there is nothing in the record suggesting

the PBGC was ever notified of the Plan's termination.            Nor, for

that matter, is there anything in the record in the form of a

notice that the assets of the Plan were sufficient to cover all

claims, required by 29 U.S.C. § 1341(b), or of a notice that the

Plan was underfunded, as provided in 29 U.S.C. § 1341(e).               The

evidence upon which National Gypsum relies, its own answers to

certain interrogatories, does not mandate a finding that the Plan

no longer exists.   We therefore conclude that the district court

did not err in finding that the Plan did not terminate.

                                III.

     In conclusion, we find that, in the particular circumstances

presented   here,   Hall's   suit        against   National   Gypsum,   as

administrator of the Plan, is equivalent to a suit against the Plan

under 29 U.S.C. § 1132(a)(1)(B) and that he is therefore entitled

to recover from the assets of the Plan. In that light, we hold that

Hall's claim is not affected by National Gypsum's discharge in


                                    17
bankruptcy.     We also hold that this suit is timely because the

denial of benefits occurred no earlier than December 1983, less

than ten years prior to the filing of Hall's complaint in May 1993.

Additionally,     we     find    that,      because    the     mechanism       for

administrative appeal was, according to National Gypsum, not in

place at the time of the denial of Hall's claim and because Hall

made efforts to secure review of the denial, National Gypsum is

equitably estopped from defending this action based upon an alleged

failure to exhaust administrative remedies.            We hold that Hall was

covered under the Plan at the time he became disabled because the

evidence     demonstrates   that      National   Gypsum      had   assured     its

employees that, for purposes of the Plan, they were not considered

terminated upon the sale of the plant to IBP. Furthermore, we

conclude that the Plan never terminated, that it continues to exist

and that National Gypsum, administrator of the Plan, is the entity

with the authority to direct payments from the Plan's assets.

Finally, because there is no dispute that Hall is vested under the

Plan and that he is disabled under the Plan, we hold that he is

entitled to benefits thereunder.

       We therefore affirm the bulk of the district court's opinion,

but vacate the judgment ordering National Gypsum itself to pay

benefits to Hall. We remand the case with directions that the court

order National Gypsum, as the administrator of the Plan, to secure

from   the   Plan's    assets   the   payment    of   benefits,    as   well    as

attorney's fees and costs of this appeal.             We are aware that the

Plan's assets are no longer in the hands of National Gypsum.                   If


                                       18
appropriate, the district court may order National Gypsum, at its

own costs, to take whatever legal steps are required to secure the

payment of benefits to Hall from the Plan's assets.

     AFFIRMED   in   part,   VACATED   in   part,   and   REMANDED   with

directions.




                                  19