Court Denies Mother’s Claim to Deceased Son’s Benefits

April 27, 2011 ( – A federal court has upheld an employer’s decision to grant death benefits to the beneficiary designated by a former employee, though his mother claimed he was unduly influenced.

The U.S. District Court for the Eastern District of Missouri concluded that the plain language of the pension plan and the 401(k) plan provide that the two death benefits are payable to Pamela Dallas who is the primary beneficiary designated by Bernard Walker on a March 24, 2000, election form. The court said the plan administrator’s decision to deny Eloise Walker benefits was supported by substantial evidence, and thus, even if another reasonable interpretation exists, the court, “may not simply substitute its opinion for that of the plan administrator.”  

Eloise Walker claimed her son acted under undue influence or as a result of fraud committed by Dallas, and submitted evidence regarding Bernard Walker’s mental health during the 1980’s and until his death. However, the court agreed with the plan administrator that Eloise Walker did not submit specific evidence of her son’s lack of mental capacity, undue influence or fraud in March 2000 when he signed the beneficiary designation card.  

The case is Trustees of the Local No. 1, IBEW Pension Benefit Trust Fund v. Wright, E.D. Mo., No. 4:10CV2114 JCH.