Williams v. Lawrence Livermore National Security

Background

Dean Williams brought a claim alleging that LLNS’s human-resources employees misrepresented or omitted information about how enrolling in disability benefits would affect his pension. The opinion discusses the claim as a breach of fiduciary duty under the Employee Retirement Income Security Act (ERISA).

Arguments and Analysis

LLNS argued that Williams’s claim was untimely under a provision in the plan stating that a claimant could not bring a court dispute about a denied claim more than one year after the benefits appeals committee issued its final decision. The court recognized that contractual limitations periods can replace ERISA’s default limitations period if they are reasonable, and noted that Williams did not argue that this period was unreasonable.

The court nevertheless held that the plan’s limitations period did not apply to Williams’s fiduciary-duty claim. The provision appeared in the plan’s section governing claims and appeals for benefits and referred to a “denied claim.” The incorporated Summary Plan Description likewise discussed claims for benefits and did not refer to breach-of-fiduciary-duty claims in connection with the limitations period. LLNS offered another possible interpretation, but the court concluded that this created, at most, an ambiguity that had to be construed against LLNS as the document’s drafter.

LLNS also argued that Williams had not alleged misrepresentations by a fiduciary. The court explained that although the LLNS HR employees were not themselves fiduciaries, their performance of fiduciary functions could be attributed to LLNS. Advising Williams about plan benefits was a fiduciary function because conveying information about the likely future of plan benefits is fiduciary conduct. The court therefore found that Williams had alleged actionable misrepresentations by a fiduciary.

Finally, LLNS argued that Williams had not adequately alleged reasonable reliance. The court found that Williams sufficiently alleged that the plan’s provisions concerning the effect of disability-benefit elections on pension benefits were ambiguous and confusing. Williams also alleged that LLNS’s HR employees had told him that the plan language was confusing.

Ruling and Next Steps

Judge Vince Chhabria denied the motion to dismiss. The order states that LLNS must file an answer within 14 days, and that a case-management conference will be scheduled for July 25, 2025.