Jacobson v. John Hancock Mutual Life Insurance Co.

Summary

The court considers plaintiffs' motion for partial summary judgment on whether John Hancock was an ERISA fiduciary under a pension plan contract. It holds that funds in the insurer's general account remain plan assets, and that the insurer may be a fiduciary when investment performance affects benefits or when it exercises control over plan management and administration. The ruling rejects the insurer's argument that ERISA's guaranteed-benefit-policy provision shields the account from fiduciary treatment.

Holdings

1. Funds contributed under GAC 738 remained ERISA plan assets to the extent their value and the benefits payable were subject to fluctuation from John Hancock's investment performance; the guaranteed-benefit-policy safe harbor applied only to the portion of the contract involving fixed guaranteed benefits or returns.
2. An insurer that manages and invests plan assets subject to investment-performance risk is an ERISA fiduciary with respect to those assets.
3. John Hancock was an ERISA fiduciary because it exercised significant discretionary control over the plan's management and administration.

Questions Presented

1. Whether funds held under the group annuity contract and invested in John Hancock's general investment account constituted ERISA plan assets before being converted into a fixed guaranteed benefit obligation.
2. Whether John Hancock was an ERISA fiduciary because it managed and invested those fluctuating funds.
3. Whether John Hancock was an ERISA fiduciary because it exercised significant discretionary control over the management and administration of the pension plan.

Disposition

dismissed