ERISA Advisory - April 2011

Reliance on plan documents does not solve all beneficiary designation problems:  Three illustrative cases.  Not long ago, the Supreme Court decided that administrators of ERISA-covered plans should not have to consult any source other than documents in their possession (such as the terms of the plan, beneficiary designations, and qualified domestic relations orders duly submitted to the plan) to determine who was entitled to benefits upon a participant's death.  Kennedy v. Plan Administrator for DuPont Savings & Investment Plan, 129 S. Ct. 865 (2009).  Part of the Court's rationale was the bright-line "plan documents rule" would facilitate plan operations by removing any need to evaluate extrinsic evidence of the participant's intent.  That reasoning was doubtless sound, but making life simpler for plan administrators is not the same as making it simple, as a trio of recent cases illustrate.