United States First Circuit

In this suit alleging that defendant's use of RAAs as a method for paying death benefits transgressed its ERISA-inspired fiduciary duties, partial summary judgment in favor of defendant is affirmed substantially on the basis of this Court's reasoning in Merrimon v. Unum Life Insurance Co., where: 1) in the circumstances of this case, the fact that the Benefits Plan did not state in haec verba that benefits would be paid by means of an RAA, unlike in Merrimon, is a distinction without difference; and 2) defendant's choice to pay by means of an RAA did not violate its fiduciary duties, as it could not be rationally argued that payment in Euros was a breach of defendant's fiduciary duty under section 404(a).

Appellate Information

• Decided 08/26/2014
• Published 08/26/2014

Judges

• Selya

Court

• United States First Circuit

Counsel