In its opinion the court pointed out that the Employee Retirement Income Security Act does not require that a plan administrator produce “any document relating to a plan,” but rather “only formal documents that establish or govern the plan.” Former Citigroup employee Elizabeth J. Carroll’s requests for documents specific to her claim for benefits do not constitute “other instruments under which the plan is established or operated,” the court said.
After being denied severance benefits, Carroll requested:
- Copies of any amendments, modifications, suspensions, or terminations, in whole or in part, of the Plan since October 15, 2003;
- Copies of the plan document, procedures, formulas, methodologies, guidelines, schedules, protocols and other guidelines;
- All documents which the plan reviewed, or could have reviewed, in denying Carroll’s claim;
- Consultant or service provider reports;
- A complete copy of the entire claim file;
- A written decision from the Plan Administrator including specific reasons for the decision and references to the provision in the Plan on which the decision was based; and
- A copy of the procedures for filing an appeal of an adverse decision.
The district court did determine that the Plans Administration Committee of Citigroup, Inc. violated ERISA by failing to produce a copy of the Plan and its Summary Plan Description within 30 days of Carroll’s request. The committee was approximately 80 days tardy in producing the documents and provided no explanation for the delay, the opinion stated.
The court said the plan administrator was subject to a monetary penalty under ERISA, but that it would determine the appropriate penalty at the time final judgment is entered on all of Carroll’s claims. In addition to the claim of failure to provide requested documents, Carroll’s suit included a claim for the denied severance benefits.