Boyd v. Metropolitan Life Insurance
636 F.3d 138
4th Cir.2011Background
- Emma C. Boyd died in November 2008; she participated in an ERISA-governed life insurance plan administered by MetLife.
- Plan documents designated Emma’s husband, Robert Alsager, as the primary beneficiary; Emma never changed this designation.
- In April 2008, a South Carolina family court separated Emma and Alsager and approved a property settlement waiving rights to each other’s estates and to life insurance proceeds.
- Although Alsager signed the separation agreement, Emma did not modify the MetLife designation, so Alsager remained the primary beneficiary on file.
- After Emma’s death, Boyds claimed benefits, while Alsager also claimed; MetLife paid the benefits to Alsager per the on-file designation and denied the Boyds’ claim.
- The district court dismissed the suit, holding MetLife fulfilled its ERISA obligations by paying benefits per the plan documents; Boyds appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plan documents rule governs benefit distribution despite a waiving agreement. | Boyds contend Alsager’s waiver should trump plan documents. | MetLife and court follow Kennedy, forbidding extrinsic waivers from overriding plan documents. | Plan documents control; waiver does not override the designation. |
| Whether Kennedy governs welfare-benefit plans as well as pension plans. | Kennedy's applicability is limited and distinguishable here. | Kennedy applies broadly to plan documents rule for benefit distribution. | Kennedy applies; plan documents govern regardless of plan type. |
| Footnote 13's relevance when no formal waiver mechanism exists in the plan. | Footnote 13 implies waiver mechanisms matter for plan administration. | Footnote 13 is not implicated because Alsager did not seek to renounce benefits; the lack of a waiver mechanism is not dispositive. | Footnote 13 is not controlling here; benefits must follow plan documents. |
| Impact of external waivers (separation agreements) on ERISA plan administration. | External waivers should affect distribution. | Administration must follow plan documents; external waivers are not controlling. | Administration followed plan documents; external waiver not controlling. |
Key Cases Cited
- Kennedy v. Plan Admin. for DuPont Savings & Investment Plan, 555 U.S. 285 (Supreme Court 2009) (plan documents rule; benefits paid per plan, not external waivers)
- Matschiner v. Hartford Life & Accident Ins. Co., 622 F.3d 885 (8th Cir. 2010) (plan documents control; footnote 13 limited)
- Carmona v. Carmona, 603 F.3d 1041 (9th Cir. 2010) (plan documents constraint after Kennedy)
- Egelhoff v. Egelhoff, 532 U.S. 141 (Supreme Court 2001) (plan documents rule foundations; avoid external documents)