ERISA NEWS; Circuit Court Adresses Failure of ERISA Plan Administrator to Disclose Plan Documents
In Odle vs. UMWA 1974 Pension Plan, the Court of Appeals for the Fourth Circuit reversed a district court’s decision on summary judgment in favor of a pension plan’s fiduciaries (in this case, the board of trustees for a coal industry multiemployer fund). The case involved a dispute over an employee’s service credit. The plan (employer) denied the claim arguing that concluding that 13.5 years of the participant’s service was actually performed in a position that was not classified as eligible under an industry-wide union agreement. The administrative record indicated that the fiduciaries based their denial, in part, on an audit of employer timesheet records that was not disclosed to the claimant. The Circuit Court (Fourth Circuit) held that an ERISA fiduciary should disclose all documents upon which a claim or appeal decision was based, unless there is a good reason not to. Such disclosure should provide the claimant with an opportunity to consider all relevant information, and use that information in making arguments in support of the claim.