Ruiz v. Publix Super Markets, Inc.
8:16-cv-00735
M.D. Fla.Mar 30, 2017Background
- Decedent Irialeth Rizo participated in Publix’s ESOP and 401(k) plans and in October 2008 executed beneficiary designation cards naming Alexander Perez‑Vargas, Andrea Vargas, and Jessica Vargas.
- Rizo was diagnosed with cancer in 2011; on January 18, 2015 she dictated a letter (signed and dated by her) changing her beneficiary to Arlene Ruiz and enclosed beneficiary cards that instead bore the notation "as stated in letter" on the signature lines. Rizo died the next day.
- Publix received the letter and cards but did not treat them as a valid beneficiary change because the beneficiary cards were not signed/dated as required by the plan SPD and, according to Publix records, the unsigned cards were returned to Rizo; Publix denied Ruiz’s claim.
- Ruiz sued under ERISA seeking plan benefits as the designated beneficiary; Publix counterclaimed for declaratory relief confirming the Vargas beneficiaries and that Publix’s denial and prior distributions were proper.
- The court conducted a de novo review of Publix’s denial, considered the equitable/federal common‑law doctrine of substantial compliance, but concluded that Kennedy and ERISA’s plan‑documents rule foreclose reliance on such doctrines to override the plan’s written requirements.
- Court granted Publix summary judgment, declared the 2008 Vargas designations controlling, denied Ruiz’s summary judgment, and entered judgment for Publix and the Vargas counter‑defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rizo’s January 18, 2015 letter and accompanying unsigned cards effected a change of beneficiary | Ruiz: Rizo manifested intent and took steps (signed dated letter, enclosed cards, identified SSN) — substantial compliance should validate the change | Publix: Plan SPD requires properly completed, signed, dated beneficiary cards; strict compliance necessary and cards were invalid | Held: No change effected; unsigned cards did not satisfy plan terms and 2008 designations control |
| Whether the federal common‑law doctrine of substantial compliance applies to override plan document requirements | Ruiz: Phoenix Mutual supports applying substantial compliance to effect a beneficiary change when intent and similar positive action are shown | Publix: Substantial compliance conflicts with ERISA’s written‑plan rule and Kennedy; plan documents must control | Held: Court found doctrine dubious post‑Kennedy and declined to apply it; plan documents govern |
| Whether equitable estoppel or oral representations by Publix altered plan requirements | Ruiz: Relies on caller’s statements that a letter would suffice and cards were less important for nonactive associates | Publix: SPD terms are unambiguous and place form/ signature requirements on participants; no reasonable ambiguity to invoke estoppel | Held: Court found SPD unambiguous; equitable estoppel not applicable |
| Whether Publix properly denied Ruiz’s claim and distributed benefits to Vargas heirs | Ruiz: Contends denial was wrong given Rizo’s intent and actions | Publix: Denial proper because plan formalities were unmet; prior 2008 designations remained effective | Held: Publix’s denial and distributions were proper; judgment for Publix and Vargas defendants |
Key Cases Cited
- Phoenix Mut. Life Ins. Co. v. Adams, 30 F.3d 554 (4th Cir. 1994) (recognizes federal common‑law substantial compliance doctrine for beneficiary changes where intent and similar positive action are evident)
- Kennedy v. Plan Administrator for DuPont Sav. & Inv. Plan, 555 U.S. 285 (2009) (ERISA requires administrators to follow plan documents; disfavors inquiry into informal expressions of intent that conflict with written plan rules)
- Fitch v. Unum Life Ins. Co. of Am., 913 F. Supp. 2d 1253 (N.D. Ala. 2012) (rejects substantial compliance in ERISA context; emphasizes written plan enforcement)
- Dunn v. Cox, 560 F. Supp. 2d 1247 (M.D. Fla. 2008) (declines to rely on substantial compliance where unsigned beneficiary form failed to meet plan signature requirement)
- Metropolitan Life Ins. Co. v. Waddell, 194 F. Supp. 3d 1340 (N.D. Ga. 2016) (applies substantial compliance analysis but finds inadequate evidence of intent/receipt to effect change)
- Bohannon v. Manhattan Life Ins. Co., 555 F.2d 1205 (5th Cir. 1977) (applies state substantial compliance principles to beneficiary form disputes)