ERISA-Seventh Circuit Affirms Decision Of Administrative Committee To Deny Benefit To Non-Spousal Beneficiary

In Estate of Jones v. Children’s Hospital and Health System, Inc. Pension Plan, No. 17-3524 (7th Cir. 2018), three days into retirement and three days before the start of her pension, Linda Faye Jones died. The Administrative Committee, which oversees the Children’s Hospital and Health System, Inc. Pension Plan, denied the pension to Linda’s daughter and beneficiary, Kishunda Jones. The Committee reasoned that only spouses are entitled to benefits under the Plan when a participant dies before the start of her pension.

In this case, the plan provides that a surviving spouse benefit is available to a participant’s spouse when the participant dies “before the Participant’s annuity starting date.” No other benefit under the plan provides that it is available to beneficiaries if the participant dies before payments start. Upon reviewing the case, the Seventh Circuit Court of Appeals (the “Court”) held that the Administrative Committee’s decision was not arbitrary or capricious.  Accordingly, the Court affirmed the Administrative Committee’s decision to deny benefit to the participant’s daughter.