George v. Junior Achievement of Central Indiana, Inc., 694 F.3d 812

Victor George, VP of Junior Achievement of Central Indiana, discovered missing deposits to his retirement and health savings accounts in 2009.
George complained to JA’s accountants and executives, including CEO Jennifer Burk, and contacted the Department of Labor without filing a written complaint.
JA later paid about $2,600 with interest after George raised concerns with JA’s board; he contemplated retiring and discussed vesting/withdrawal timing.
JA terminated George effective December 31, 2009, while he asserts an amended employment agreement changed his vesting date to December 1, 2009.
George withdrew the deferred-compensation funds; JA demanded restoration and argued the discharge remained valid.
District court granted summary judgment for JA on ERISA §510 claim and dismissed state-law claims; this appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does §510 protect informal complaints as ‘inquiries’?	George's informal communications constituted protected information to be included in an inquiry.	§510 protects only formal inquiries or proceedings, not informal complaints.	Yes; §510 covers informal inquiries as part of protected activity.
Does George's grievance about fiduciary breach qualify as an inquiry or proceeding under §510?	Grievances and questions about fiduciary duties fall within ‘inquiry’ when they prompt employer response.	Only formal inquiries or proceedings trigger §510 protection.	Grievances fall within §510's inquiry scope; protection applies.
Should the district court's dismissal be affirmed or remanded for further proceedings?	The district court erred in construing §510 too narrowly and should allow trial on causation.	The statute's text supports a limited, formal view of inquiry and dismissal was proper.	Judgment vacated and remanded for proceedings consistent with the opinion.

Kasten v. Saint-Gobain Performance Plastics Corp., 131 S. Ct. 1325 (Supreme Court 2011) (interpretation of §510 scope including informal retaliation)
Edwards v. A.H. Cornell & Son, Inc., 610 F.3d 217 (3d Cir. 2010) (informal vs formal inquiries under §510)
Nicolaou v. Horizon Media, Inc., 402 F.3d 325 (2d Cir. 2005) (scope of retaliation provisions under ERISA)
Hashimoto v. Bank of Hawaii, 999 F.2d 408 (9th Cir. 1993) (unsolicited complaints as retaliation protections)
Neal v. Honeywell Inc., 33 F.3d 860 (7th Cir. 1994) (antes in retaliation contexts under ERISA)
Crawford v. Metropolitan Government of Nashville, 555 U.S. 271 (Supreme Court 2009) (opposition to unlawful practices protected whether spontaneous or in response to questions)
Central States, Southeast and Southwest Areas Pension Fund v. Central Transport, Inc., 472 U.S. 559 (Supreme Court 1985) (fiduciary duties and investigations in ERISA context)