Schmidt v. Sheet Metal Workers’ National Pension Fund

Allen Schmidt was a beneficiary of a pension plan run by the Sheet Metal Workers’ National Pension Fund (fund) (defendant). Allen was diagnosed with terminal cancer and wanted to designate his son, Richard Schmidt (plaintiff), as the sole death beneficiary of his pension benefits. The two men called the fund and spoke with a benefit analyst to determine how to make Richard the sole beneficiary. During a phone call, the analyst said he would send a form for Allen to complete that would designate Richard as the plan’s sole beneficiary. The analyst, however, sent the wrong form; the proper form was in a pension-plan booklet. Allen later died having never submitted the proper booklet form. Under the terms of the plan, the pension benefit would be split evenly between Richard and Allen’s other child absent the proper booklet form being filed. The fund therefore denied Richard’s requests to be named the sole beneficiary after Allen’s death. Richard sued the fund, claiming that (1) the fund was estopped from following the plan’s written terms requiring the booklet form because of the analyst’s mistake and (2) the analyst’s mistake constituted a breach of the fund’s fiduciary duties under the Employee Retirement Income Security Act of 1974 (ERISA). The district court granted summary judgment for the fund, and Richard appealed.