Estate of Barton v. ADT, No. 13-56379 (9th Cir. 2016)
Annotate this CaseBruce Barton filed suit against ADT under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1132, seeking claims related to his request for pension benefits. On appeal, Barton challenges the district court's conclusion that the Plan Administrator did not abuse its discretion in denying Barton’s request for pension benefits. The court concluded that the district court incorrectly placed the burden of proof on Barton for matters within defendants’ control. The court held that where a claimant has made a prima facie case that he is entitled to a pension benefit but lacks access to the key information about corporate structure or hours worked needed to substantiate his claim and the defendant controls such information, the burden shifts to the defendant to produce this information. The district court correctly held that to recover statutory penalties based on a plan administrator’s refusal to comply with ERISA’s disclosure obligations, a plaintiff must qualify as a plan participant. The court reversed and remanded for the district court to apply the now-clarified burden of proof in this case.
Court Description: Employee Retirement Income Security Act. The panel reversed the district court’s judgment after a bench trial in favor of the defendants in an action under the Employee Retirement Income Security Act, challenging a denial of pension benefits on the basis that the plaintiff did not have sufficient years of service with an employer or its affiliates. The panel held that the burden of proving entitlement to benefits was not properly placed on the plaintiff because the defendants were in a better position to ascertain whether an entity was a participating employer in the ERISA plan. The panel held that when a claimant has made a prima facie case that he is entitled to a pension benefit but lacks access to the key information about corporate structures or hours worked needed to substantiate his claim, and the defendant controls such information, the burden shifts to the defendant to produce this information. The panel remanded the case to the district court to apply the correct burden of proof. Dissenting, Judge Ikuta wrote that the majority’s burden- shifting rule was contrary to the abuse of discretion review applicable to the plaintiff’s claim. ESTATE OF BARTON V. ADT 3
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