Cozen O'Connor, P.C. v. Tobits

Sarah Farley married Jennifer Tobits in Canada in 2006. Farley and Tobits’s marriage was authorized and solemnized under Canadian law. The validity of Farley and Tobits’s Canadian marriage was undisputed. Farley and Tobits were residents of Illinois, which recognized all valid same-sex marriages performed in other jurisdictions. Farley worked at the law firm of Cozen O’Connor (Cozen) (plaintiff) and was a participant in Cozen’s profit-sharing plan (Cozen’s plan), an Employee Retirement Income Security Act (ERISA) qualified retirement plan. Farley died in 2010. Pursuant to the terms of Cozen’s plan, as required by ERISA, the plan administrator must pay benefits to the surviving spouse of a deceased plan participant in the form of a pre-retirement survivor annuity. If the surviving spouse did not want to receive death benefits, the benefits had to be waived in writing. If the deceased participant did not have a surviving spouse, the benefits would be paid to the participant’s parents or designated beneficiary. Farley did not designate a beneficiary, and Tobits did not waive her right to receive surviving-spouse benefits. Farley’s parents, David and Joan Farley (the Farleys), and Tobits both requested payment of Farley’s death benefits. Cozen filed an interpleader action naming Tobits and the Farleys as defendants in order to determine the appropriate recipient of Farley’s death benefits.