Fourth Circuit Rejects Widow’s Claim For Equitable Relief

The Fourth Circuit recently rejected fiduciary breach and equitable estoppel claims for life insurance coverage by Leslie Moon, the widow of a deceased employee, who claimed that the employer's actions resulted in Mr. Moon's failure to convert his life insurance to an individual policy following the onset of his disability. In so ruling, the Court determined that Leslie Moon failed to establish that the employer was a fiduciary of the life insurance plan because: (i) the employer's alleged failure to alert Mr. Moon that he was no longer covered under the plan and its continued acceptance of Mr. Moon's premium payments (when such payments should have been made directly to the insurer) constituted administrative, not fiduciary, functions; and (ii) the plan was administered by third party. The case is Moon v. BWX Techs., Inc., No. 13-cv-1888, 2014 U.S. App. LEXIS 12525 (4th Cir. July 2, 2014).