Eleventh Circuit Releases Long-Awaited Decision on ERISA Sanctions


The Eleventh Circuit just confirmed their outlook on the Employee Retirement Income Security Act of 1974, or ERISA. The new decision in Williamson v. Travelport, LP 953 F. 3d 1278 (11th Cir. 2020), illuminated the latitude of document requests which ignite ERISA’s § 1132(c) penalty provisions and the method in which requests are made. Section 1132(c) of ERISA imposes a sanction for a plan administrator’s inability or refusal to deliver vital information “which [the] administrator is required by this subchapter to furnish to a participant…” The documents demand ERISA plan administrators to encompass the most up-to-date summary plan description, the newest annual report, any bargaining agreement, any terminal report, contract, trust agreement or any other instrument under which the company’s plan is recognized.

Nonetheless, a few plaintiffs seek sanctions under § 1132(c) for documents that do not fall within § 1024(b)(4), like original or historical documents and documents underlying a pension plan benefit calculation, among various others. Per the case, the Eleventh Circuit ruled the penalties under § 1132(c) “cannot be imposed for failure to provide documents other than those specifically enumerated in § 1024(b)(4).” Hence, the court then vetoed the plaintiff’s contention that sanctions were presented for failures to manufacture employment history and claims-specific, such as Labor Department rules and alleged breaches of ERISA § 209(a) as well as 29 U.S.C. § 1059(a) guidelines.

At last, the court avowed the dismissal of the plaintiff’s recent claims, but reversed the dismissal of the benefits claim under § 1132(a)(1)(B) with attorney’s costs under § 1132(g)(1), and remanded to the district court. By doing so, the court determined that the district court inadequately ruled on the plaintiff’s merits in the § 1132(a)(1)(B) claim, as the plaintiff unearthed plausible claims for relief and the court did not have the entire administrative record when it decided to dismiss the motion.

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