Boyd v. ConAgra Foods, Inc., No. 16-1763 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's grant of summary judgment in favor of ConAgra in an action seeking to recover severance benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that ConAgra's financial conflict of interest was still a relevant factor the court considered in determining whether ConAgra abused its discretion in denying plaintiff's claim; ConAgra did not abuse its discretion in determining that plaintiff lacked good reason to self-terminate; and because ConAgra's decision was reasonable, ConAgra did not abuse its discretion in denying plaintiff's claim for benefits. Furthermore, ConAgra did not breach its fiduciary duty to plaintiff by misstating or omitting certain material information when communicating with him. Finally, the court held that plaintiff's claims were not frivolous and affirmed the award of attorney's fees incurred by plaintiff.
Court Description: Melloy, Author, with Wollman and Gruender, Circuit Judges] Civil case - ERISA. In action to recover severance benefits based on a claim that defendant, after acquiring Ralcorp, plaintiff's former employer, had materially reduced his position, duties or responsibilities, thereby allowing him to self-terminate and obtain the benefits, the district court did not err in reviewing the Plan Administrator's decision under an abuse-of-discretion standard; giving any potential conflict of interest defendant had as both the plan sponsor and administrator some weight, the decision that plaintiff lacked good reason to self-terminate his employment was reasonable and was not an abuse of the Plan Administrator's discretion; the district court did not err in finding defendant did not breach a fiduciary duty to plaintiff as plaintiff did not show that he had right to reasonable rely on a claimed misstatement; the law suit was not frivolous, and plaintiff was entitled, under the provisions of the Plan, to recover his attorney's fees.
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