Conkright v. Frommert
Issues
Whether a district court must defer to an ERISA plan administrator’s proposed remedy for an ERISA violation, where the violation resulted from a prior interpretation by the plan administrator.
Courts generally give deference to discretionary decisions made by ERISA pension plan administrators. This case will test the limits of that deference and will decide if a court is obligated to defer to a plan administrator’s proposed remedy for an ERISA violation, when the cause of the violation itself was the administrator’s prior interpretation. Petitioners and their amici argue that allowing judges to involve themselves in ERISA pension plan determinations without deferring to decisions made by the plan administrator will increase the costs and uncertainty of maintaining pension plans. Respondents and their amici, on the other hand, argue that deferring repeatedly to a plan administrator will increase costs through more and prolonged litigation, and will be unfair to plan participants who justifiably rely on promised benefits to plan for retirement.
Questions as Framed for the Court by the Parties
1. Whether the Second Circuit erred in holding, in conflict with decisions of thisCourt and other Circuits, that a district court has no obligation to defer to an ERISA plan administrator's reasonable interpretation of the terms of the plan if the planadministrator arrived at its interpretation outside the context of an administrativeclaim for benefits.
2. Whether the Second Circuit erred in holding, in conflict with decisions of other Circuits, that a district court has "allowable discretion" to adopt any "reasonable"interpretation of the terms of an ERISA plan when the plan interpretation issue arises in the course of calculating additional benefits due under the plan as a result of an ERISA violation.
The Employee Retirement Income Security Act (“ERISA”), 29 U.S.C.