Justia ERISA Opinion Summaries

After Marvin Crowder died, Fidelity disbursed his plan benefits to his sister as his designated beneficiary. Plaintiff, Marvin's ex-wife, filed suit under the Employee Retirement Income Security Act (ERISA), alleging claims of wrongful denial of benefits and breach of fiduciary duty.The Eleventh Circuit affirmed the district court's dismissal of plaintiff's ERISA claims, holding that the Plan Administrator correctly interpreted the Plan and that, after her divorce, plaintiff had no entitlement to her ex-husband's benefits under the Plan's terms. Because plaintiff was not a "beneficiary" under Section 14.03 of the Plan, she failed to state a plausible claim for wrongly denied benefits. Likewise, plaintiff's claims for breach of fiduciary duty failed because she was not a "beneficiary" under the Plan and defendants owed no ERISA-imposed duties to her. Furthermore, plaintiff also lacked statutory authorization to bring a claim for equitable relief based on defendants' alleged breach of their fiduciary duties. View "Crowder v. The Delta Air Line, Inc. Family-Care Savings Plan" on Justia Law

Plaintiff filed a class action against Travelport and the Galileo & Worldspan U.S. Legacy Pension Plan under the Employee Retirement Income Security Act of 1974, alleging claims for improperly withheld pension benefits, document-disclosure penalties, and breach of fiduciary duties. The district court dismissed all claims.With respect to plaintiff's claim for benefits, the Eleventh Circuit reversed and remanded for the district court to review her claim anew after Travelport has certified and submitted the complete and accurate administrative record. The court reversed the district court's award of attorney's fees, but otherwise affirmed the district court's judgment. View "Williamson v. Travelport, LP" on Justia Law

Metlife initiated this interpleader action under Federal Rule of Civil Procedure 22, seeking to pay into the registry of the district court the proceeds of an insurance policy on the life of the deceased. Defendants were the deceased's widow, a minor child of the deceased, and the temporary administrator of the estate. The deceased purchased the policy at issue to fund the Plan he had established as its sole member and trustee pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The Eleventh Circuit held that MetLife deposited the proper amount into the district court registry and therefore affirmed the district court's order to the extent it addressed that issue. The court also held that the district court properly denied the administrator's renewed motion to enforce the settlement. However, the court remanded the action to the district court to address the issue of attorney fees in the first instance. View "MetLife and Annuity Company of Connecticut v. Akpele" on Justia Law

Section 1113(1)'s statute of repose in the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 11131(a), is subject to express waiver. In this interlocutory appeal, the Eleventh Circuit was asked to answer a certified question regarding whether defendant was capable of expressly waiving the six-year statute of repose pursuant to section 1113(1). The court answered the certified question in the affirmative. The court reasoned that, because section 1113(1) does not erect a jurisdictional bar, it was presumptively waivable. Moreover, the court explained that there was no good reason to conclude that section 1113(1) cannot be expressly waived simply because it is a statute of repose. The court remanded for further proceedings. View "Secretary, U.S. Department of Labor v. Preston" on Justia Law