It appears that there is a growing trend among circuit courts to give meaning to ERISA’s breach of fiduciary remedies, even when benefits are claimed as a result of that breach. The opinion below is against AT&T, an entity that has a self-funded ERISA plan that it administers.
Plaintiff brought this action under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., against AT&T after her claim to recoup her lost benefits was denied. The district court found that AT&T unreasonably denied plaintiff’s claim and failed to adequately notify her of a material change to its pension plan that allowed her to collect full benefits earlier than she had originally understood. The court held that the district court properly considered limited evidence outside of the administrative record but known to AT&T when it rendered plaintiff’s benefits determination; correctly determined that AT&T breached its statutory and fiduciary duties to plaintiff; and did not err in awarding plaintiff her lost benefits. Accordingly, the court affirmed the judgment.