BAFFORD V. ADMINISTRATIVE CMTE. OF THE NORTHROP GRUMMAN PLAN, No. 22-55634 (9th Cir. 2024)
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The case involves pension plan participants, Evelyn Wilson and Stephen Bafford, who alleged that the plan administrator, the Administrative Committee of the Northrop Grumman Pension Plan, violated the Employee Retirement Income Security Act (ERISA) by not providing pension benefit statements automatically or on request, and by providing inaccurate pension benefit statements prior to their retirements. The district court initially dismissed the case, but on appeal, the Ninth Circuit Court of Appeals affirmed in part and vacated in part the dismissal, allowing the plaintiffs to file amended complaints.
Upon remand, the plaintiffs filed amended complaints, but the district court dismissed their claims again. The plaintiffs appealed once more to the Ninth Circuit Court of Appeals. The Ninth Circuit held that the lower court's prior mandate did not preclude the plaintiffs from pleading their claim for violation of ERISA on remand. The court also held that the plaintiffs stated a viable claim under ERISA by alleging that the plan administrator provided substantially inaccurate pension benefit statements.
The court rejected the administrator’s argument that there were no remedies available for the ERISA violations the plaintiffs alleged. As a result, the Ninth Circuit reversed the district court’s dismissal of the plaintiffs’ claims and remanded the case for further proceedings.
Court Description: Employee Retirement Income Security Act The panel reversed the district court’s dismissal of an action brought by pension plan participants, alleging that the plan administrator violated the Employee Retirement Income Security Act by not providing pension benefit statements automatically or on request, and by providing inaccurate pension benefit statements prior to the participants’ retirements.
In an earlier appeal, the court affirmed in part and vacated in part an earlier dismissal. On remand, plaintiffs filed amended complaints. The panel held that the court’s prior mandate did not preclude plaintiffs from pleading, on remand, their claim for violation of 29 U.S.C. * Judge Desai was drawn at random to replace Judge Bea. Judge Desai has reviewed the briefs, the record, and the recording of oral argument. BAFFORD V. ADMIN. COMM. OF THE NORTHROP GRUMMAN PLAN 3 § 1025(a)(1)(B)(i) in the plan administrator’s failure to provide them with pension benefit statements every three years or with annual notices of the availability of such statements. The panel further held that plaintiffs stated a § 1025(a)(1)(B)(i) claim.
The panel held that plaintiffs also stated a claim under § 1025(a)(1)(B)(ii), which requires administrators to furnish pension benefit statements in response to participants’ written requests. The panel concluded that plaintiffs’ claim that the administrator provided substantially inaccurate pension benefit statements was cognizable under § 1025(a)(1)(B)(ii). The panel also concluded that plaintiffs adequately pleaded an ERISA violation based on their allegation that they made written requests sufficient to trigger the duty to produce pension benefit statements. The panel rejected the administrator’s argument that there were no remedies available for the ERISA violations plaintiffs alleged.
Accordingly, the panel reversed the district court’s dismissal of plaintiffs’ claims under § 1025(a)(1)(B)(i)- (b)(ii) and remanded for further proceedings.
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