Wengert v. Rajendran, No. 16-4571 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's grant of summary judgment against plaintiff in an action seeking funds from her husband's trust that was transferred from an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001-1461, plan. The husband had requested the "Accrued Benefit" amount from his ERISA employee-benefit plan be transferred to his trust days before he passed away. Applying an abuse of discretion standard to this case, the court held that the plan administrative committee reasonably explained its interpretation and relied on substantial evidence to deny plaintiff's claim. Therefore, the committee did not abuse its discretion when it determined that the relevant inquiry was not when funds were received by a participant, but rather when funds were transferred out of the plan.
Court Description: Benton, Author, with Shepherd and Kelly, Circuit Judges] Civil case - ERISA. District court properly applied an-abuse-of-discretion standard to the Plan's construction of this ERISA plan; Plan Administrator's determination that under the Plan the relevant inquiry for determining when a transfer has been made is not when the funds are received by the participant but rather when the funds were transferred out of the Plan was not an abuse of discretion.
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