Appleton v. Alcorn

Summary

The Supreme Court of Georgia held that a surviving spouse's receipt of ERISA-governed retirement and life insurance benefits did not bar the decedent's children from pursuing a state-law breach of contract claim based on an alleged waiver in a separation agreement. ERISA's protections applied while the benefits were under the plan administrator's control, but did not preclude claims against the beneficiary after distribution. The court affirmed the Court of Appeals' reversal of the trial court's dismissal.

Holdings

1. ERISA does not preclude a state-law breach-of-contract claim against the beneficiary to recover ERISA-covered benefits after the benefits have been paid out and are no longer under the control of the plan administrator.
2. Kennedy v. Plan Administrator for DuPont Savings & Investment Plan did not require dismissal of the appellees' state-law claim against Appleton because Kennedy addressed claims against the employer and plan administrator before or in connection with distribution, while expressly reserving whether an action could be brought against the beneficiary after distribution.

Questions Presented

1. Whether ERISA precludes a state-law breach-of-contract action against a beneficiary to recover ERISA-governed benefits after the plan administrator has distributed the benefits to that beneficiary.
2. Whether Kennedy v. Plan Administrator for DuPont Savings & Investment Plan required dismissal of the appellees' state-law claim because the settlement-agreement waiver was not an ERISA-compliant waiver or qualified domestic relations order.

Disposition

affirmed