Summary
The Minnesota Supreme Court held that state and federal courts have concurrent jurisdiction to review an ERISA plan administrator’s determination of whether a proposed domestic relations order is qualified. The court concluded that an alternate payee designated in the order qualifies as a beneficiary for purposes of jurisdiction and that the claim could proceed under ERISA’s benefits provision. The court reversed the court of appeals and remanded for further proceedings.
Topics
Practice areas
Questions Presented
- Whether state courts have subject matter jurisdiction concurrent with federal courts to review a plan administrator's determination that a proposed domestic relations order is not a qualified domestic relations order under ERISA.
- Whether an alternate payee designated in a domestic relations order is a beneficiary for purposes of ERISA section 1132(a)(1)(B) even when the plan administrator has not determined that the order is qualified.
- Whether Langston's claim was an action under ERISA section 1132(a)(1)(B), for which state and federal courts have concurrent jurisdiction, rather than solely an action under section 1132(a)(3), for which federal jurisdiction is exclusive.
Holdings
- State and federal courts have concurrent subject matter jurisdiction to review a plan administrator's determination of whether a domestic relations order is a qualified domestic relations order under ERISA.
- An alternate payee designated in the 2005 domestic relations order qualifies as a beneficiary for purposes of establishing subject matter jurisdiction to obtain judicial review, even though the plan administrator had not determined that the order was qualified.
- Langston's claim was not solely an action under ERISA section 1132(a)(3); it also sought to recover benefits and enforce rights under the terms of the pension plan and the state domestic-relations order, bringing it within section 1132(a)(1)(B) and concurrent state-court jurisdiction.
Key quotations
“In conclusion, we hold that state and federal courts have concurrent jurisdiction to review a plan administrator's determination of whether a domestic relations order is "qualified" for purposes of ERISA and that the state district court properly heard Langston's claims pursuant to section 1132(a)(1)(B).” (at 693)
“Jurisdiction, therefore, is not defeated as respondents seem to contend, by the possibility that the averments might fail to state a cause of action on which petitioners could actually recover.” (at 691)
Factual background
The Anoka County District Court dissolved Gary and Patricia Langston's marriage in 1993 and awarded Patricia a one-half interest in the marital portion of Gary's pension benefits, including required survivor benefits. In 2005, the district court issued a domestic relations order implementing the dissolution judgment, but the pension plan administrator refused to qualify it because the benefits were already in pay status and advised that Patricia could receive some benefits through a revised order. Patricia did not submit a revised order and instead sued the plan and administrator, obtaining a default judgment requiring recognition of the 2005 order.
Procedural history
After the district court entered a 2005 domestic relations order concerning Patricia Langston's interest in pension benefits, the plan administrator refused to qualify the order. Langston first moved to enforce the order in the dissolution proceeding, but that motion was denied because the plan and administrator were not parties and the court lacked personal jurisdiction over them. She then filed a separate action against the plan and administrator, obtained a default judgment, and the district court denied respondents' motion to vacate. The court of appeals reversed, but the Minnesota Supreme Court reversed the court of appeals on subject matter jurisdiction and remanded.
Remand instructions
Reverse the court of appeals' judgment on subject matter jurisdiction and remand for further proceedings consistent with the opinion. Because the court of appeals' vacatur of the district court's default judgment was not appealed, the district court must vacate the default judgment on remand.