936 F.3d 853
8th Cir.2019Background
- Terry Engle, an employee of Land O'Lakes, died without a designated beneficiary; his employer's ERISA plans were administered by Unum, which had discretionary authority to interpret the plans and determine benefits.
- Plan language allowed payment to the decedent's estate or to a "spouse" (in a prioritized list), and elsewhere the plans stated that "'spouse' wherever used includes domestic partner" in coverage sections.
- Engle's mother, Sharon, told Unum Engle had no estate; Sharon identified two minor children and Jaclyn Jones as Engle's domestic partner; Unum sought and received an affidavit from Jones and paid her $266,000.
- Sharon later opened an estate, sued claiming Unum should have paid the estate (i.e., the children), and a district court ruled against Unum, finding Unum unreasonably interpreted the plan and that Jones failed to meet domestic-partner designation requirements.
- The Eighth Circuit reviewed de novo whether Unum’s interpretation was reasonable given the plan language and Unum's discretionary authority.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the term "spouse" in benefits-payment provisions includes "domestic partner" | Sharon: "spouse" does not apply outside coverage headings; enlargement limited to coverage context | Unum: "wherever used" is broad; "spouse" includes domestic partners in benefits provisions | Court: Unum's literal reading is a reasonable interpretation; payment permissible |
| Whether Jones satisfied the plan's domestic-partner designation requirement | Sharon: Jones was not designated by Engle, so she cannot qualify as a domestic partner for benefits | Unum: Designation requirement governs insurance-coverage eligibility, not benefits payment; requirement is limited by its own wording | Court: Unum's distinction is reasonable; designation language plausibly limited to coverage context |
| Standard of review for plan administrator's interpretation | Sharon: district court should reject Unum's reading as unreasonable | Unum: deference due where administrator has discretionary authority | Court: Apply deferential abuse-of-discretion standard; administrator's reasonable choices upheld |
| Whether equity/speculation about decedent's wishes controls distribution | Sharon: Engle would have wanted proceeds to his children | Unum: Plans control distribution; speculation is irrelevant | Court: Distribution governed by written plan; speculation insufficient to override administrator's reasonable interpretation |
Key Cases Cited
- Manning v. Am. Republic Ins. Co., 604 F.3d 1030 (8th Cir. 2010) (standard for reviewing administrator decisions under ERISA)
- Donaldson v. Nat'l Union Fire Ins. Co. of Pittsburgh, 863 F.3d 1036 (8th Cir. 2017) (administrator's choice among reasonable interpretations not an abuse of discretion)
- Admin. Comm. of Wal-Mart Stores, Inc. Assocs.' Health & Welfare Plan v. Shank, 500 F.3d 834 (8th Cir. 2007) (ERISA protects interests defined by the written plan)
- Conkright v. Frommert, 559 U.S. 506 (2010) (deference to plan administrators preserves ERISA's balance and promotes administrative finality)
Outcome: Reversed district court; judgment entered for defendants (Unum and Land O'Lakes).