Justia ERISA Opinion Summaries

Bruce Barton filed suit against ADT under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1132, seeking claims related to his request for pension benefits. On appeal, Barton challenges the district court's conclusion that the Plan Administrator did not abuse its discretion in denying Barton’s request for pension benefits. The court concluded that the district court incorrectly placed the burden of proof on Barton for matters within defendants’ control. The court held that where a claimant has made a prima facie case that he is entitled to a pension benefit but lacks access to the key information about corporate structure or hours worked needed to substantiate his claim and the defendant controls such information, the burden shifts to the defendant to produce this information. The district court correctly held that to recover statutory penalties based on a plan administrator’s refusal to comply with ERISA’s disclosure obligations, a plaintiff must qualify as a plan participant. The court reversed and remanded for the district court to apply the now-clarified burden of proof in this case. View "Estate of Barton v. ADT" on Justia Law