WDNY — ERISA — Plan Summary: Miles v. Corning Inc. Long Term Disability Plan

U.S. District Court, WDNY

ERISA — Plan Summary

Breach of Fiduciary Duty — Speculative Harm

Miles v. Corning Inc. Long Term Disability Plan
12-cv-6063L
Judge Larimer

Background: The plaintiff, a former employee of Corning Incorporated and a participant in its long term disability plan, brought an action against the plan, claiming that her long term disability benefits payments were improperly and prematurely discontinued. The plaintiff seeks review of the denial of the disability claim, a declaratory judgment declaring that the plaintiff is entitled to the benefits sought, and, in the alternative, equitable relief in the event that the court determines that the arbitrary and capricious standard of review applies to the benefit denial. The defendant moved to dismiss the plaintiff’s request for equitable relief.

Ruling: The District Court granted the defendant’s motion. The court held that in order to plausibly allege a failure to provide a plan summary as required by ERISA, the plaintiff must plausibly allege that the plan administrator had a fiduciary duty to the plaintiff; that the fiduciary breached that duty; and that actual harm resulted, which may take the form of detrimental reliance, unjust enrichment, or the loss of a right protected by ERISA. The court noted that the failure to provide a plan summary is not sufficient to be considered a harm to the plaintiff. The plaintiff’s allegation that she missed an opportunity to seek alternative coverage because she lost the opportunity to read the plan summary is speculative.

E. Peter Pfaff for the plaintiff; Thomas E. Reidy for the defendants