In Kingsbury v. Marsh &McLennan Companies, Inc., No. 11-1253 (1st Cir. 2012) (Unpublished Opinion), the plaintiff, Joan Kingsbury (“Kingsbury”), was appealing the district court’s grant of summary judgment affirming the denial by a plan administrator of a claim for retirement benefits purportedly owed to Kingsbury’s deceased sister, Lorna Hutcheon (“Hutcheon”), under ERISA. The district court’s judgment was based on the grounds that Kingsbury’s claim was barred by the statute of limitations, and that the decision of the plan administrator to deny the claim was not arbitrary and capricious.
In analyzing the case, the First Circuit Court of Appeals (the “Court”) said that, with respect to a plan administrator’s decision, where an ERISA plan gives the administrator discretion to determine benefit eligibility or to construe the terms of the plan, and the plan administrator makes a benefit determination under the plan, a court will reverse the administrator’s decision only when it is arbitrary, capricious, or an abuse of discretion.
Here, the plan administrator based its decision on its finding that the employer’s records did not contain any evidence that Hutcheon, alleged to be an employee from 1956 to 1977, had any entitlement to the retirement benefits in question. The Court found that the plan administrator’s decision to deny Kingsbury’s claim was measured and well considered, since the plan had exerted substantial effort researching the claim and searching for evidence of Hutcheon’s purported entitlement to the retirement benefits, and it received and considered evidence from the Kingsbury supporting Hutcheon’s entitlement. The Court could not conclude that the plan administrator’s denial of the claim was arbitrary, capricious, or an abuse of discretion. Accordingly, the Court affirmed the district court’s summary judgment against Kingsbury, and did not need to reach the statute of limitations issue.