Sznewajs v. U.S. Bancorp Amended & Restated Supplemental Benefits Plan
Court of Appeals for the Ninth Circuit · 2009-07-13 · cited 39×
This case involves a dispute over the interpretation of an ERISA-governed top hat supplemental benefits plan for executives, specifically which spouse qualifies as the designated survivor beneficiary under a joint and survivor annuity after the participant's divorce and remarriage. The plan administrator concluded that the second wife was the proper beneficiary based on its reading of the plan's reference to "retirement," but the district court ruled for the ex-wife. The Ninth Circuit determined that abuse of discretion review applied because the plan documents granted the administrator discretionary authority and no conflict of interest was present at the time of the decision. It held that the administrator's interpretation of the ambiguous term was reasonable and therefore permissible, reversing the district court's judgment and remanding for entry of summary judgment in the plan's favor.