Lebahn v. National Farmers Union Uniform Pension Plan, 828 F.3d 1180

Lebahn contacted pension-plan consultant Eloise Owens to calculate his monthly pension; Owens reported $8,444.18 and reverified that figure on request.
Lebahn retired and received monthly payments at that rate, but the plan later informed him he had been overpaid and that his true benefit was $3,653.78; he was asked to return overpayments.
Lebahn and his wife sued under ERISA alleging breach of fiduciary duty and equitable estoppel, relying on Owens’ misstatements; the district court dismissed for failure to state a claim.
On appeal the key factual allegation was that Owens performed benefit calculations and communicated them to participants; plaintiffs argued that this made her an ERISA fiduciary and that the plan should be estopped from reclaiming overpayments.
The Tenth Circuit reviewed the Rule 12(b)(6) dismissal de novo and affirmed, holding Owens was not a fiduciary based on the pleadings and that the estoppel claim failed for lack of adequately pleaded justifiable reliance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a pension-plan consultant who calculates and reports benefits is an ERISA functional fiduciary (discretionary authority/responsibility)	Owens’ role in calculating and communicating benefits makes her a functional fiduciary under 29 U.S.C. §1002(21)(A)	Routine calculation and reporting are ministerial tasks without discretionary authority; thus not fiduciary acts	Calculating and reporting benefits alone do not confer ERISA fiduciary status; affirmed dismissal of breach claim
Whether equitable estoppel prevents the plan from recouping overpayments	Plaintiffs relied on Owens’ representations and should be estopped from repayment	Plaintiffs failed to plead justifiable detrimental reliance (and plan documents unambiguously state formula)	Estoppel dismissed; plaintiffs did not challenge district court’s independent finding of no justifiable reliance, so dismissal affirmed

Varity Corp. v. Howe, 516 U.S. 489 (1996) (misleading communications can give rise to fiduciary liability where fiduciary authority over plan administration exists)
CIGNA Corp. v. Amara, 563 U.S. 421 (2011) (equitable relief under §502(a)(3) requires showing of detrimental reliance for estoppel-type remedies)
Moore v. Lafayette Life Ins. Co., 458 F.3d 416 (6th Cir. 2006) (providing materially misleading plan information can constitute breach of fiduciary duty)
Sprague v. General Motors Corp., 133 F.3d 388 (6th Cir. 1998) (discussion whether explanations to retirees could implicate fiduciary capacity; dicta on fiduciary status)
Schmidt v. Sheet Metal Workers’ Natl. Pension Fund, 128 F.3d 541 (7th Cir. 1997) (ministerial administrative tasks do not by themselves create fiduciary status)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard requires plausibility)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (labels-and-conclusions insufficient under Rule 8)
Mocek v. City of Albuquerque, 813 F.3d 912 (10th Cir. 2015) (appellate standard for Rule 12(b)(6) review)