Mead Vest v. Resolute FP US Inc., 905 F.3d 985

Arthur Vest worked ~40 years for Resolute and purchased $300,000 in optional group life insurance in addition to base coverage.
He stopped working in September 2015 due to diabetes and began receiving long-term disability benefits; under the Plan base coverage continued but optional coverage ended when active employment ceased.
The Plan allowed conversion/porting of expiring optional coverage to an individual policy within 31 days; Resolute terminated Arthur’s optional coverage on May 18, 2016.
Resolute did not notify Arthur of his 31-day conversion right; he died in October 2016 and the beneficiary (Mead Vest) received only base coverage proceeds.
Mead Vest sued under ERISA § 502(a)(3), alleging Resolute breached fiduciary duties by failing to inform Arthur of conversion rights; the district court dismissed for failure to state a claim and the Sixth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Resolute breached an ERISA fiduciary duty to disclose conversion rights	Vest: Resolute had a duty to inform Arthur (or knew silence might be harmful) and failed to notify him of 31-day conversion right	Resolute: No duty to disclose beyond ERISA-required SPD; no misleading statement/omission that would trigger fiduciary liability	Court: No. Complaint failed to plead facts fitting recognized disclosure exceptions in Sprague/Krohn; dismissal affirmed
Whether an employer’s voluntary communications that omit conversion info can create fiduciary liability under Sprague’s "own-initiative" prong	Vest: Voluntary Benefits Summary omitted a material conversion deadline and thus was misleading	Resolute: No obligation to provide conversion notice beyond SPD; omission not actionable absent specific misleading statement or prior inquiry	Court: Plaintiff did not allege a misrepresentation or facts showing Resolute knew silence would be harmful; claim insufficiently pleaded

Haviland v. Metro. Life Ins. Co., 730 F.3d 563 (6th Cir. 2013) (articulates contours of ERISA fiduciary disclosure duties and summarizes Sprague categories)
Sprague v. Gen. Motors Corp., 133 F.3d 388 (6th Cir. 1998) (en banc) (defines three circumstances where fiduciary disclosure duty may be breached)
Krohn v. Huron Mem'l Hosp., 173 F.3d 542 (6th Cir. 1999) (holds fiduciary must give complete and accurate information once beneficiary's situation is known)
James v. Pirelli Armstrong Tire Corp., 305 F.3d 439 (6th Cir. 2002) (applies Sprague’s own-initiative analysis; employer may be liable if it provides misleading plan information)
Gregg v. Trans. Workers of Am. Int'l, 343 F.3d 833 (6th Cir. 2003) (applies Krohn question-and-response pattern for disclosure duties)
Eddy v. Colonial Life Ins. Co. of Am., 919 F.2d 747 (D.C. Cir. 1990) (beneficiary’s known predicament triggers fiduciary duty to disclose all material facts)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: allegations must state a plausible claim)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading requires sufficient factual matter to state a plausible claim)