In Boyd v. ConAgra Foods, Inc., Nos. 16-1763 and 16-3443 (8th Cir. 2018), James Boyd, a former employee of ConAgra Foods, Inc., brought this action under ERISA. Boyd seeks to recover severance benefits under an ERISA plan that guarantees these benefits when ConAgra, in certain circumstances, materially reduces an employee’s position, duties, or responsibilities. Boyd alternatively claims that ConAgra breached its fiduciary duty by misleading him about his employment. The district court granted ConAgra summary judgment on these claims and then granted Boyd his attorney’s fees, pursuant to the plan’s terms.
The Eighth Circuit Court of Appeals (the “Court”) affirmed the district court’s rulings. As to the claim to recover benefits, the Court said that ConAgra’s decision to not pay the severance benefits is entitled to a deferential review. The Court found that ConAgra’s decision was reasonable, and held that ConAgra did not abuse its discretion in denying Boyd’s claim for the benefits. As to the claim of breach of fiduciary duty, the Court said that .Boyd did not show that he reasonably relied, to his detriment, on any material misrepresentation or omission.