United States Ninth Circuit

In this ERISA interpleader action seeking a determination as to the proper beneficiary of proceeds under two employee benefit plans, the plan participant formally designated defendant ex-wife as his beneficiary, and after their divorce, designated defendant son as his beneficiary over the telephone but did not sign and return beneficiary designation forms. The district court's summary judgment in favor of the ex-wife is reversed and remanded, where: 1) the beneficiary designation forms were not "plan documents" governing the plan administrator's award of benefits under 29 U.S.C. section 1104(a)(1)(D); and 2) there was a triable issue as to whether, under state law, the plan participant strictly or substantially complied with the governing plan documents' requirements for changing his beneficiary designation.

Appellate Information

• Decided 01/28/2015
• Published 01/28/2015

Judges

• O'Scannlain

Court

• United States Ninth Circuit

Counsel