Mays-Williams v. Williams, No. 13-35069 (9th Cir. 2015)
Annotate this CaseBefore his retirement, Asa Williams, Sr. participated in various benefit programs (the Xerox Plans), which are subject to the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Asa married Carmen and designated Carmen as his beneficiary. After their divorce, Asa attempted to change his designated beneficiary from his ex-wife to his son (Asa, Jr.). After Asa, Sr.'s death, Carmen claimed to be the beneficiary under the Xerox Plans and Asa, Jr. likewise asserted the same claim. Carmen subsequently moved for summary judgment, asserting that because Asa, Sr. failed to fill out and to return the beneficiary designation forms, he did not properly designate Asa, Jr. as beneficiary in her place. The district court granted the motion. The court concluded that the district court erred in determining that Asa, Sr. was required to abide by the language contained in the forms - but not in the governing plan documents - to change his beneficiary from Carmen to Asa, Jr. Reviewing de novo whether Carmen or Asa, Jr. is entitled to plan benefits, the court concluded that based on the evidence, including Xerox's call log reflecting that Asa, Sr. called Xerox to change his beneficiary designation from Carmen to Asa, Jr., a reasonable trier of fact could determine that Asa, Sr. intended to change his beneficiary to Asa, Jr. and that his phone calls to Xerox constituted substantial compliance with the governing plan documents' requirements for changing his beneficiary designation. Accordingly, the court reversed and remanded.
Court Description: Employee Retirement Income Security Act. The panel reversed the district court’s summary judgment in an ERISA interpleader action seeking a determination as to the proper beneficiary of proceeds under two employee benefit plans. The plan participant formally designated his wife as his beneficiary. After their divorce, he designated his son as beneficiary over the telephone but did not sign and return beneficiary designation forms. The panel held that the beneficiary designation forms were not “plan documents” governing the plan administrator’s award of benefits under 29 U.S.C. § 1104(a)(1)(D). The panel concluded that 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. The panel remanded the case for further proceedings. MAYS-WILLIAMS V. WILLIAMS 3
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