This case centered on a Southwest Research Institute (SWR) researcher’s election to reduce his life insurance benefits from $500,000 to $100,000 two-and-a-half years before his death. Dr. Slater made the election after a battle with brain cancer that left him with some memory loss. Id. at 1-2. His widow alleged that a year later, when she discovered the reduced death benefit, Dr. Slater had no recollection of making the change and was “visibly upset” by it. Id. at 2.
After the typical skirmishing over ERISA preemption, Dr. Skinner’s widow amended her complaint to assert that SWR breached its ERISA fiduciary duties to Dr. Skinner by (a) failing to oversee his benefit election, (b) failed to abide by the work restrictions his physician imposed, and (c) changing life insurance providers during the pendency of the Slaters’ ERISA appeal. Id. at 5.
ERISA imposes fiduciary duties on employers only to the extent they exercise discretionary authority with respect to a benefits program. Slip op. at 4. The District Court concluded that (a) the three areas Ms. Slater cited did not implicate any ERISA discretionary authority, and (b) lack of evidence and other legal principles precluded Ms. Slater’s claims. Id. at 5-9. Therefore, the District Court dismissed Ms. Slater’s claims by summary judgment. Id. at 10.