Court Rejects Children as Intended Beneficiaries of ESOP Participant

In its ruling, the court said the plan did not abuse its discretion in denying the children’s claim for benefits since the plan gave the administrator discretion to interpret plan provisions and the evidence supports its decision.

The court also determined there were no issues of material fact to support the plaintiffs’ claim. According to the court opinion Roy Robinson’s alleged visit to the plan’s Web site did not prove he intended to change his beneficiary designation or that he interpreted the Web site’s language to mean his children were his default beneficiaries.

In January 1998, Robinson submitted a beneficiary designation form designating his sister as sole beneficiary of his ESOP benefits, according to the court document.

The plaintiffs claimed that sometime after 1998 MeadWestvaco hired Hewitt Associates to administer a Web site for its benefit plans and all plan decisions by participants occurred online after that. The plaintiffs said Robinson visited the Web site sometime in 2003.

According to the opinion, the plaintiffs allege the site included language asserting that all beneficiary elections previously made on paper were invalid and listing children first as default beneficiaries if no election was made by an unmarried participant. The plaintiffs argued that Robinson read this language and assumed his children would receive his benefits if he died.

Following Robinson’s death in 2004, Hewitt denied the children’s claim to benefits and set up an account for his sister. The children’s mother filed a lawsuit claiming Hewitt abused its discretion when making its decision.

The court disagreed and granted summary judgment for the plan and Robinson’s sister, noting that Robinson took no actions to change his beneficiary on the site and there was no way to know of his intent or how he interpreted the site’s language.

The case is Robinson v. MeadWestvaco.