When Oliver Gibbs applied for benefits to the Central States, Southeast and Southwest Areas Pension Fund, he falsely claimed his wife, Daisy Cobb, was deceased. At the time, the two had been separated for 13 years. According to the facts in the opinion, Gibbs’ choice to not select the joint and survivor benefits option on the plan meant that he would get $675 each month in lifetime benefits, rather than the $588 he would have received had he added Cobb to the plan.
Gibbs started receiving benefits in 1979.
Cobb filed a claim with the plan two decades after her husband’s death, arguing that she was entitled to the survivor benefits, but Central States rejected it on the grounds that Gibbs did not opt for joint and survivor benefits. The plan stated that “[a]ll Pension Benefits provided by this Plan shall be paid directly to the Pensioner, and not to any creditor or other person not eligible for the such benefits.”
After exhausting all administrative processes to get Gibbs’ benefits, Cobb filed a suit against Central States in the US District Court for the Eastern District of Louisiana, which found for the plan.
The appeals court said that ERISA defines a beneficiary as a “person designated by a participant, or by the terms of any employee benefit plan, who is or may become entitled to a benefit thereunder.” The court’s decision to deny joint and survivor benefits to Cobb hinges on the fact that her husband did not designate her as the beneficiary.
For the full opinion in Daisy Estelle Cobb v. Central States, Southwest and Southeast Areas Pension Fund is here .