877 F.3d 698
6th Cir.2017Background
- Bruce Jackson enrolled in an ERISA-governed employer life insurance plan in 2003 and named his uncle, Richard Jackson, as beneficiary.
- Bruce and Bridget divorced in 2006; their separation agreement (incorporated in the divorce decree) required each parent to maintain employer-provided life insurance naming their minor child, Sierra (born 1995), as primary beneficiary until she turned 18 or graduated high school.
- Bruce never changed the policy beneficiary; he died in 2013 while Sierra was still in high school.
- Sun Life, the plan administrator, paid the proceeds to Richard and sought a declaratory judgment that its payment was proper. Sierra counterclaimed that the divorce decree qualified as a Qualified Domestic Relations Order (QDRO) under ERISA and entitled her to the proceeds.
- The district court awarded the proceeds to Sierra; Sun Life appealed.
Issues
| Issue | Jackson (Plaintiff) Argument | Sun Life (Defendant) Argument | Held |
|---|---|---|---|
| Whether a post-1985 domestic relations order must "clearly specify" statutory details to qualify as a QDRO | The 2006 decree, read in full, clearly specifies participant, alternate payee, amount, period, and plans — satisfying §1056(d)(3)(C) | Sun Life contends a lenient or contextual standard should not apply; it argues ambiguity and lack of literal specificity preclude QDRO status | Court holds post-1985 orders must meet the statute's "clearly specifies" standard, but the standard allows contextual, common-sense reading of the entire order rather than rigid magic words. |
| Whether the divorce decree here clearly specifies the participant and alternate payee (names and addresses) | The decree and incorporated separation agreement identify Bruce and Sierra and list mailing addresses | Sun Life argues the documents are ambiguous about who/which addresses are covered | Held: Names and addresses are sufficiently specified through the agreement and parenting plan. |
| Whether the decree clearly specifies the amount/percentage and applicable period (payments/term) | The agreement requires maintenance of "all employer-provided life insurance" naming the minor child as primary beneficiary, and sets the period (until 18 or high school graduation) | Sun Life argues ambiguity about which plans (basic vs optional), timing, and "reasonable cost" qualification create uncertainty | Held: The language reasonably specifies 100% of proceeds and the applicable period; "all" covers basic and optional employer-provided coverage. |
| Whether plaintiff's remedy is precluded by remedial clause, alleged noncompliance, or late notice | Jackson argues ERISA allows enforcement of the decree as a QDRO irrespective of parental noncompliance or post-death notice, and counsel provided Sun Life the order before payment | Sun Life argues the decree's remedial clause limits child to probate claims, that parents failed to comply, and notice was untimely | Held: Remedial clause and parents' noncompliance do not defeat Sierra's ERISA QDRO claim; posthumous or late notice to plan administrator does not bar a QDRO claim here. |
Key Cases Cited
- Metro. Life Ins. Co. v. Marsh, 119 F.3d 415 (6th Cir. 1997) (pre-1985 orders judged by substantial compliance; limited to pre-REA orders)
- Metro. Life Ins. Co. v. Bigelow, 283 F.3d 436 (2d Cir. 2002) (adopted Marsh's approach for pre-1985 orders)
- Yale-New Haven Hosp. v. Nicholls, 788 F.3d 79 (2d Cir. 2015) (examining QDRO sufficiency and posthumous orders)
- Kennedy v. Plan Adm’r for DuPont Sav. & Inv. Plan, 555 U.S. 285 (2009) (discussing plan administration and uniformity under ERISA)
- Metro. Life Ins. Co. v. Wheaton, 42 F.3d 1080 (7th Cir. 1994) (endorsing literal reading of §1056(d)(3)(C) and emphasizing specificity)
- Hawkins v. Comm’r of Internal Revenue, 86 F.3d 982 (10th Cir. 1996) (refusing to accept less than statute's express requirements)
- Hamilton v. Wash. State Plumbing & Pipefitting Indus. Pension Plan, 433 F.3d 1091 (9th Cir. 2006) (requiring that dissolution orders clearly contain statutory information; cautioning against overly expansive interpretations)
- Files v. ExxonMobil Pension Plan, 428 F.3d 478 (3d Cir. 2005) (QDRO may be pursued posthumously)
- FDIC v. Dover, 453 F.3d 710 (6th Cir. 2006) (unpublished decisions are non‑precedential and bind only the parties)