Boyd v. ConAgra Foods, Inc., No. 16-1763 (8th Cir. 2018)Annotate this Case
The 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.