Helton v. AT & T Inc., 709 F.3d 343

Helton, an AT&T employee since 1980, left on a leave in 1997 and became a deferred vested pensioner under AT&T's Pension Plan.
In 1997 AT&T amended the plan via a Special Update allowing early full benefits at age 55 without reduction; Helton claims she did not receive related notices (Burlingame letter, 1998 SPD).
In 2009 Helton learned she could have begun full benefits earlier and sought retroactive relief; AT&T denied and later the Benefits Committee denied retroactive benefits in 2010.
The district court found AT&T unreasonably denied benefits and improperly failed to notify her of a material change, ordering retroactive benefits and declaratory relief on related claims.
AT&T argued on appeal that extrinsic evidence should not be considered, that the denial was reasonable, and that Amara prevented retroactive relief; the court affirmed, upholding retroactive benefits and related findings.
During proceedings, the court admitted extrinsic evidence known to AT&T and found deficiencies in the administrative record, including failures to verify mailings and the 1998 SPD distribution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether extrinsic evidence can be considered under abuse-of-discretion review	Helton argues extrinsic evidence known to AT&T should be considered to evaluate Booth factors.	AT&T contends outside-record evidence is barred under Sheppard and related precedent.	Extrinsic evidence may be considered when known to the administrator and necessary to Booth factors.
Whether AT&T abused its discretion in denying retroactive benefits	Helton asserts denial was unreasonable given administrative failures and plan language permitting corrective action.	AT&T contends its interpretation and record support denial were reasonable under plan terms.	AT&T abused its discretion; Helton is entitled to retroactive benefits.
Appropriate remedy after abuse of discretion	Helton seeks retroactive benefits as full relief for the misinforming conduct.	AT&T argues remand to the administrator would be appropriate.	Remand not required; retroactive benefits awarded as remedy.
ERISA disclosure obligations for a material plan change	Helton contends AT&T failed to notify of the Special Update and 1998 SPD to her.	AT&T maintains proper disclosures were made or not required for deferred vested pensioners in certain contexts.	AT&T violated ERISA disclosure requirements by failing to ensure actual receipt of notices.

Booth v. Wal-Mart Stores, Inc. Assocs. Health & Welfare Plan, 201 F.3d 335 (4th Cir. 2000) (multifactor abuse-of-discretion test for ERISA plan decisions)
Williams v. Metro. Life Ins. Co., 609 F.3d 622 (4th Cir. 2010) (detail on deference and record review under discretionary plans)
Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989) (standard of review depends on discretionary language in plan)
Sheppard & Enoch Pratt Hosp. v. Travelers Ins. Co., 32 F.3d 120 (4th Cir. 1994) (extrinsic evidence consideration when known to administrator; abuse standard)
Murphy v. Deloitte & Touche Group Ins. Plan, 619 F.3d 1151 (10th Cir. 2010) (recognizes exceptions to no-extrinsic-evidence rule for conflicts of interest)