Justia ERISA Opinion Summaries

The Supreme Court held that the Employee Retirement Income Security Act of 1974 (ERISA), 19 U.S.C. 1001 et seq., and in particular, ERISA's anti-alienation statute, shields a 401K plan administrator from state garnishment liability.Florence Lake Investments, LLC obtained a judgment against Jason Berg and his wife, Mary Berg, and made several collection efforts through postjudgment proceedings for garnishment or execution. Florence served garnishment interrogatories on Zoetis, Inc., as administrator of Berg's 401K account, but Zoetis did not disclose its role regarding Berg's 401K account. Florence then filed an application to determine garnishee liability against Zoetis. The court overruled the application, concluding that Zoetis was not liable for failing strictly to comply with the garnishment statutes by not disclosing Berg's 401K because ERISA governed the account, and therefore, the account could not be subject to garnishment. The Supreme Court affirmed, holding (1) ERISA's anti-alienation statute prevented Florence from acquiring Berg's right to the funds in his 401K account; and (2) therefore, Zoetis could not be held liable for failing to comply with the garnishment statutes. View "Florence Lake Investments v. Berg" on Justia Law