Sherry L. Miller v. Campbell Soup Company Retirement & Pension Plan Administrative Committee

1 QUESTIONS] PRESENTED The Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, 88 Stat. 829, as amended, 29 U.S.C. § 1001 et seqg., was enacted to protect plan _ participants and beneficiaries by imposing fiduciary duties, requiring fnancial disclosures, and affording ready access to federal courts. ERISA governs both retirement and welfare benefit plans. The questions presented are:

1. Whether ERISA permits fiduciaries to enforce 4 state-law general release as a condition of receiving welfare benefits, where the release bars plan-wide fiduciary breach claims under 29 U.S.C. § 1132, despite (A) fiduciaries’ failure to disclose material misrepresentations that caused long-term harm to participants lacking actual knowledge, and (B) a structural conflict of interest in which the same agent adjudicated benefit claims and managed the release, extinguishing fiduciary breach claims. 29 U.S.C. §§ 1104, 1106, 1109, 1110, 1113, 1132, 1144.

2. Whether ERISA permits fiduciaries to enforce the written terms of a pension plan against participants when the plan’s actual operations materially deviate from those terms in violation of ERISA’s fiduciary and disclosure requirements. 29 U.S.C. §§ 1102, 1104.

3. Whether a court violates ERISA’s procedural protections by dismissing a fiduciary breach claim as “moot”? based on a general release without first determining whether material evidence undermines the release’s validity or supports a substantive fiduciary breach, and thereby nullifying the totalityof-circumstances analysis that such evidence would have required. Fed. R. Civ. P. 8, 26, 56, 60.