956 F. Supp. 2d 711
W.D. Va.2013Background
- ERISA plan administered by MetLife for BWX employees; Moon’s life insurance benefit of $200,000 under the 2006 Confirmation Statement; Moon retired in 2005 and died in 2006; Plaintiff paid portion of 2006 premiums but not all; district court previously dismissed AM claims and the Fourth Circuit partly affirmed and remanded to address equitable remedies (Amara, McCravy II); on remand the court denied leave to amend and granted motion to dismiss for failure to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Plaintiff may amend Counts One and Two to seek equitable remedies. | Amara/McCravy II authorize equitable remedies. | Remand did not authorize reformation/surcharge; amendments futile. | Amendment denied; futile as to reformation/surcharge. |
| Whether Plaintiff can sustain a breach of fiduciary duty claim. | Defendants acted as fiduciaries by handling plan-related payments. | Defendants were not fiduciaries for these activities; no discretionary control. | Breach of fiduciary duty claim fails; not fiduciaries for alleged acts. |
| Whether Plaintiff can pursue equitable estoppel. | Estoppel available because defendants acted as fiduciaries. | No fiduciary status; estoppel unavailable without fiduciary relation. | Equitable estoppel claim fails; no fiduciary status established. |
| Whether proposed amendments seeking reformation and surcharge are futile. | Reformation/surcharge remedies may be available under Amara/McCravy II. | Remand guidance does not permit these remedies; not applicable here. | Reformation and surcharge futile; amendment denied. |
Key Cases Cited
- Amara v. Cigna Corp., 131 S. Ct. 1866 (U.S. 2011) (remedies under ERISA § 1132(a)(3) include equitable relief (reformation))
- McCravy v. Metropolitan Life Insurance Co., 690 F.3d 176 (4th Cir. 2012) (recognizes surcharge/equitable remedies under 1132(a)(3))
- Estate of Weeks v. Advance Stores Co., Inc., 99 Fed.Appx. 470 (4th Cir. 2004) (administrative not fiduciary acts; misinforming benefits not fiduciary breach)
- Wilmington Shipping Co. v. New England Life Ins. Co., 496 F.3d 326 (4th Cir. 2007) (fiduciary status defined by discretionary control over plan)
- Coleman v. Nationwide Life Ins. Co., 969 F.2d 54 (4th Cir. 1992) (defines ERISA fiduciary duties and scope)