District Court Considers Evidence Outside Administrative Record
Ellis & Winters
Helton v. AT&T, Inc.
No. 11—2153, 2013 WL 812118 (4th Cir. Mar. 6, 2013)
In Helton v. AT&T, Inc., the Fourth Circuit Court of Appeals affirmed the district court’s consideration of evidence outside of the administrative record but known to AT&T and its determination that AT&T, Inc. and the AT&T Pension Benefit Plan (collectively “AT&T”) breached their statutory and fiduciary duties to Francine Helton.
Helton worked for AT&T until May 1997. When Helton left AT&T, she was a deferred vested pensioner and was not eligible to receive benefits until she turned 65. In August 1997, AT&T amended Helton’s plan to allow certain participants, including Helton, to elect benefits at age 55 without facing any benefit reduction. Under this amendment, Helton was entitled to begin receiving full pension benefits in October 2001. AT&T attempted to notify eligible individuals by mailing communications in 1997 and 1998. Helton testified that she did not receive either of these communications or any other pension-related notice from AT&T.
In 2009, after first learning that she had been entitled to begin collecting her full pension benefits nearly eight years earlier, Helton contacted her pension plan seeking to recoup her lost benefits. The administrator denied Helton’s request, stating that under the plan’s terms, the benefits were not retroactively payable. Thereafter, Helton appealed the administrator’s denial of benefits to AT&T’s Employee Benefits Committee. The committee denied her appeal, affirming the administrator’s decision that retroactive benefits were unavailable under the terms of the plan. Helton subsequently filed suit against AT&T. Following a bench trial, the district court found that AT&T unreasonably denied Helton’s claim and failed to adequately notify her of a material change to its pension plan that allowed her to collect full benefits earlier than she had originally understood.
The Fourth Circuit agreed. In doing so, the Fourth Circuit held that
a district court may consider evidence outside of the administrative record on abuse of discretion review in an ERISA case when evidence is necessary to adequately assess the [factors set forth in Booth v. Wal-Mart Stores, Inc. Associates Health & Welfare Plan, 201 F.3d 335 (4th Cir. 2000)] and the evidence was known to the plan administrator when it rendered its benefits determination.
The Fourth Circuit also found that the district court’s determination that AT&T did not adequately notify Helton was not clearly erroneous, given the lack of evidence that the 1997 and 1998 communications had been mailed to her.