Delker v. Mastercard International, Inc., No. 20-3600 (8th Cir. 2022)
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Plaintiff filed suit against MasterCard for life insurance benefits under MasterCard's employee benefits plan, alleging breach of fiduciary duty under the Employee Retirement and Income Security Act (ERISA), breach of contract, and fraud.
The Eighth Circuit reversed the district court's grant of summary judgment in favor of MasterCard on plaintiff's breach of fiduciary claim, concluding that plaintiff plausibly alleged that his wife elected a total amount of three times her salary in life insurance, for which MasterCard promised to pay premiums. The court explained that, if that proves true, MasterCard's failure to pay premiums would constitute a breach of the fiduciary duty it owed its employees participating in its ERISA-governed benefit plan. Furthermore, plaintiff plausibly alleged that, if his wife's election was in fact deficient for any reason, MasterCard's materially misleading statements caused her to reasonably believe that she had elected three times her salary in life insurance, premiums paid by her employer, and to rely upon that belief in declining to purchase additional life insurance as she was entitled to do. The court affirmed as to the remaining claims and concluded that amendment would be futile.
Court Description: [Smith, Author, with Gruender and Stras, Circuit Judges] Civil case - ERISA. Plaintiff plausibly alleged that his wife, defendant's employee, had elected a total amount of three times her salary in life insurance, for which defendant had promised to pay the premiums; if that proves true, defendant's failure to pay the premiums would constitute a breach of a fiduciary duty it owed its employees participating in the company's ERISA-governed benefit plan; plaintiff further alleged defendant's materially misleading statements caused his wife to reasonably believe she had made the election and that she relied on those statements; the district court erred therefore in dismissing plaintiff's claim for breach of fiduciary duty.
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