Judge Baer
http://nycourts.law.com/CourtDocumentViewer.asp?view=Document&docID=117266
PLAINTIFFS were beneficiaries under ERISA-governed plans, funded with group life insurance policies from Metropolitan Life Insurance Co., providing for a Total Control Account (TCA) to distribute death benefits. MetLife retains and invests interest bearing money-market funds. Death benefits are deposited into the TCA after a beneficiary presents a check for payment. Contending that MetLife earns more managing and investing funds than it pays in interest to beneficiaries, plaintiffs’ putative class action alleged MetLife’s use of a TCA was breach of fiduciary duty under ERISA. The court dismissed the complaint, ruling that the way in which MetLife administered plaintiffs’ TCAs complied with ERISA and did not breach fiduciary duties. MetLife’s compliance with the provision for distribution of death benefits through establishment of a TCA did not immunize it from liability. However, plaintiffs’ full receipt of all benefits they were entitled to barred a fiduciary duty breach claim. Under Wright v. Oregon, where a fiduciary complies with a plan’s lawful terms and provides the beneficiaries the benefits they were due under the plan, there is no violation of 29 USC §1104(a)’s “exclusive purpose” requirement.
