Krebsbach v. Travelers Pension Plan, The

Background

Judith M. Krebsbach asserted claims under the Employee Retirement Income Security Act of 1974 concerning The Travelers Pension Plan. She has worked for The Travelers Companies, Inc. for almost fifty years and remains employed there. She participates in the Plan, a qualified defined-benefit plan. The parties agree that Krebsbach is entitled to the larger available lump-sum benefit, but they disagree about how to calculate it.

Krebsbach’s amended complaint included two counts. Count I sought benefits due under 29 U.S.C. § 1132(a)(1)(B), including a determination of which benefit calculation is correct. Count II alleged breaches of fiduciary duty under 29 U.S.C. § 1132(a)(3). The alleged breaches involved choosing plan interpretations favorable to Travelers, providing an insufficient summary plan description, and failing to provide prompt, complete, and accurate information. Krebsbach sought equitable remedies, including surcharge or make-whole relief, reformation of the Plan, a remand for a full and fair review, and attorneys’ fees and costs.

Motion and legal standard

The defendants moved for partial judgment on the pleadings under Federal Rule of Civil Procedure 12(c), arguing that Krebsbach was not entitled to the remedies sought under Count II. The court applied the same standard used for a motion to dismiss for failure to state a claim. At this stage, the court assumed well-pleaded factual allegations were true and asked whether the complaint contained enough facts to state a plausible claim for relief.

Court’s analysis

The court held that Count I and Count II were based on different theories of liability and therefore were not improperly duplicative at the pleading stage. A benefits claim concerns benefits due under the Plan, while the fiduciary-duty claim seeks equitable relief for alleged breaches of fiduciary obligations. The court concluded that Krebsbach could plead both claims so long as she did not obtain duplicate recoveries.

The court also determined that the requested surcharge based on alleged lost rights was sufficiently pleaded. It explained that ERISA protects a participant’s right to accurate and comprehensive plan information and that an insufficient summary plan description can itself constitute an injury. Krebsbach alleged that the summary plan description was unclear and that different experts reached different benefit calculations based on it. The court found those allegations plausible.

The court held that attorneys’ fees sought for the alleged failure to provide prompt, complete, and accurate information were not duplicative of fees associated with the benefits claim. It distinguished fees related to litigating benefits due from fees allegedly caused by a breach of fiduciary duty.

The court rejected surcharge based on detrimental reliance because Krebsbach identified only lost benefits as the harm from that reliance, which would duplicate relief sought under Count I. The court also rejected reformation. Reformation is an equitable remedy for a contract that fails to express the parties’ agreement because of circumstances such as fraud or mutual mistake. Krebsbach did not allege that the Plan failed to express the parties’ agreement, fraud, or mutual mistake.

Disposition

The court ordered that the defendants’ motion for judgment on the pleadings was GRANTED IN PART and DENIED IN PART. It was granted as to Krebsbach’s claims for surcharge under a theory of detrimental reliance and for reformation, and those claims were DISMISSED WITH PREJUDICE. It was denied as to surcharge under a theory of lost rights and attorneys’ fees to remedy the alleged breaches of fiduciary duty under Count II.