516 F. App'x 468
6th Cir.2013Background
- ERISA SSIP benefits; McDonald died with vested SSIP account and no SSIP beneficiary named.
- Life-insurance beneficiaries on McDonald’s policy were Mancuso and McHone; SSIP distributions initially went to Mancuso and McHone.
- SPD and SSIP Plan allowed designation via a specific Beneficiary Form; Fidelity/ Ford administered the process.
- Liss claimed she was the rightful SSIP beneficiary based on a completed Fidelity form and McDonald’s expressed wishes.
- Fidelity and the Ford Committee denied Liss’s claim for lack of proper form; district court held Liss not the beneficiary and remanded for record development on SPD furnishing.
- Court remands to determine whether the SPD was properly furnished to McDonald; constructive trust issue remains discretionary after that determination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Liss is the proper SSIP beneficiary given form deficiencies | Liss asserts proper designation via the Fidelity form. | Committee denied due to incorrect form submission. | denied; Committee’s decision not arbitrary or capricious based on form rules. |
| Whether SPD governs and binds plan terms when Amara is considered | SPD supports Liss’s interpretation of designation requirements. | SPD communicates procedures but does not change plan terms; no conflict with Amara. | SPD properly relied on; not arbitrary or capricious. |
| Whether the SPD was properly furnished to McDonald | Record lacks evidence that SPD was furnished to McDonald. | Record not conclusive; ERISA does not require issue-exhaustion. | remand to develop record on furnishing. |
| Whether a constructive trust should be imposed on funds distributed to Mancuso and McHone | Funds traced to McDonald’s SSIP; constructive trust warranted. | Discretionary; depends on SPD furnishing determination. | For district court to decide after SPD furnishing issue is resolved. |
| Scope of de novo/abuse-of-discretion review given discretionary Administration Committee | Discretion should weigh motives and procedures. | Committee acted with discretion; review under arbitrary-and-capricious standard. | Court reviews for reasoned explanation; discretionary standard applies. |
Key Cases Cited
- Kennedy v. Plan Adm’r for Dupont Sav. and Inv. Plan, 555 U.S. 285 (U.S. 2009) (SPD can be a governing document (not the plan terms) under ERISA)
- Amara, CIGNA Corp. v. Amara, 131 S. Ct. 1866 (Sup. Ct. 2011) (SPD not necessarily binding as “terms” of the plan)
- DeLisle v. Sun Life Assurance Co. of Canada, 558 F.3d 440 (6th Cir. 2009) (establishes de novo review framework when discretionary authority exists)
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (U.S. 1989) (sets standard for discretionary review under plan terms)
- Bidwell v. Univ. Med. Ctr, Inc., 685 F.3d 613 (6th Cir. 2012) (supports treating SPD as instrument governing terms when consistent with plan)
- McCorkle v. Bank of Am. Corp., 688 F.3d 164 (4th Cir. 2012) (no Amara conflict where procedures do not contradict the plan)
- Foster v. PPG Indust., Inc., 693 F.3d 1226 (10th Cir. 2012) (reaffirmed use of SPD procedures when not conflicting with plan)
- Crosby v. Rhom & Hass Co., 480 F.3d 423 (6th Cir. 2007) (statements in SPD can be binding)
- Kennedy v. Plan Adm’r for Dupont Sav. and Inv. Plan, 555 U.S. 285 (U.S. 2009) (reference for plan documents governing ERISA)