Skinner v. Northrop Grumman Retirement Plan B
673 F.3d 1162
9th Cir.2012Background
- ERISA plaintiffs Skinner and Stratton challenged Northrop Plan B as the successor to Litton Plan B.
- The district court granted summary judgment; on appeal, this court previously found an ambiguity between SPD language and master documents regarding the annuity equivalent offset.
- Supreme Court in Amara limited the effect of SPDs, holding they do not form the plan terms for § 502(a)(1)(B).
- Plaintiffs seek equitable relief under § 502(a)(3) (estoppel, reformation, surcharge) after conceding no reliance on the SPD.
- Court holds summary judgment was appropriate; plaintiffs’ reformation and surcharge theories fail under Amara and ERISA.
- Court addresses whether relief can be granted for breach of fiduciary duty through an inaccurate SPD and the remedies available under § 502(a)(3).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Amara forecloses §502(a)(1)(B) relief. | Skinner/Stratton rely on Amara’s dicta to allow other relief. | Amara holds SPDs are not plan terms; §502(a)(1)(B) claim fails. | Yes; Amara forecloses the §502(a)(1)(B) relief. |
| Whether reforming the master documents is permissible. | Reformation should reflect drafter's true intent as indicated by the 2003 SPD. | No evidence of fraud or mutual mistake; cannot reform. | No; reformation not warranted. |
| Whether fraud/mistake supports reformation under trust or contract principles. | Fraud/mistake by plan drafter invalidating term alignment. | No evidence of fraud, duress, or misrepresentation; SPD created after plan. | No; fraud/mistake not shown. |
| Whether surcharge or unjust enrichment remedies lie for failure to provide accurate SPD. | Breach could justify surcharge for benefits gained or harm caused. | Plaintiffs did not rely on SPD; no harm shown; SPD not plan terms. | Not warranted; no compensable harm or unjust enrichment. |
| Whether plaintiffs relied on the SPD and suffered harm to justify equitable relief. | Relience on SPD alleged but undisputed. | Explicitly conceded no reliance; harms not shown. | Relied on SPD not shown; relief denied. |
Key Cases Cited
- Amara v. CIGNA Corp., 131 S. Ct. 1866 (2011) (SPD not part of plan terms; Amara limits remedies under § 502(a)(3) when SPDs misstate terms)
- Bergt v. Retirement Plan for Pilots Employed by MarkAir, Inc., 293 F.3d 1139 (9th Cir. 2002) (ambiguous SPD vs. master document can create triable issue)
- Banuelos v. Construction Laborers' Trust Funds for Southern California, 382 F.3d 897 (9th Cir. 2004) (confirms limits on SPD-based relief post-Amara)
- American President Lines, Ltd. v. United States, 821 F.2d 1571 (Fed. Cir.1987) (meeting of minds concept in contract interpretation for reformation)
- Schongalla v. Hickey, 149 F.2d 687 (2d Cir.1945) (early authority on reformation concepts in contract-like plans)