The Verizon Employee Benefits Committee v. Nikolaros
1:23-cv-01982
| E.D.N.Y | Mar 18, 2025Background
- Nick Nikolaros was a Verizon employee who died in 2020; he participated in a Verizon pension plan.
- In 2001, Nick named his then-wife, Parthena Nikolaros, as his primary pension plan beneficiary, and his sister, Georgia Nikolaros, as contingent beneficiary.
- Nick and Parthena divorced in 2017; the divorce was accompanied by a settlement incorporated into a court order.
- After the divorce, Nick did not update his beneficiary designations or remarry before his death.
- Verizon filed an interpleader action asking the court to determine entitlement to the plan’s death benefit, naming the estate, Parthena, and Georgia as claimants.
- All parties moved for summary judgment on their respective claims to the death benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of Georgia's Status as Beneficiary | Designation void by plan at participant's 35th birthday | Designation should remain effective | Georgia not a valid beneficiary; designation void at age 35 |
| Validity of Parthena's Status Post-Divorce | Divorce revoked Parthena's designation absent QDRO | Divorce settlement constitutes QDRO/right to part of benefit | Parthena not a valid beneficiary; settlement not a QDRO |
| Entitlement of Estate to Benefit | Estate entitled if no valid beneficiary at death | N/A | Estate is sole beneficiary under plan terms |
| Effect of Divorce Settlement on Benefits | Settlement excludes death benefits; QDRO required for assignment | Settlement provides right to benefits/share of death benefits | Settlement not a valid QDRO; does not assign death benefits |
Key Cases Cited
- Aramony v. United Way of Am., 254 F.3d 403 (2d Cir. 2001) (plan interpretation uses federal common law, looking to plain meaning)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (standard for surviving summary judgment)
- Frost v. N.Y.C. Police Dep’t, 980 F.3d 231 (2d Cir. 2020) (summary judgment standard application)
- Metro. Life Ins. v. Bigelow, 283 F.3d 436 (2d Cir. 2002) (subject matter jurisdiction in ERISA interpleader actions)
- Int’l Multifoods Corp. v. Com. Union Ins., 309 F.3d 76 (2d Cir. 2002) (contract interpretation under New York law)