Schuett v. FedEx Corporation

Stacey Schuett (plaintiff) had been in a relationship with her partner, Lesly Taboada-Hall, for over 27 years. Hall worked for FedEx Corporation (defendant) for 26 years and was a participant in the company’s pension plan (the plan), which was governed by the Employee Retirement Income Security Act of 1974 (ERISA). The plan required FedEx to pay a qualified joint and survivor annuity to the surviving spouse of a participant who died before retirement. The plan defined spouse by reference to the United States Code, which defined spouse as a husband or wife of the opposite sex. In February 2010, Hall was diagnosed with cancer, and on June 3, 2013, Hall was informed that her cancer was terminal. On June 13, Schuett and Hall were told that Schuett would not receive the surviving-spouse benefit because of the plan’s definition of spouse. On June 19, Hall and Schuett were married. Hall died the following day. At that time, California was not issuing marriage licenses for same-sex couples. Within the next few weeks, the Supreme Court struck down the Defense of Marriage Act, and the United States Court of Appeals for the Ninth Circuit lifted a stay on an order directing California officials to stop enforcing Proposition 8, a statewide ban on same-sex marriages. On September 18, at Schuett’s request, a county superior court issued an order declaring that the marriage between Hall and Schuett had occurred on June 19, 2013, and also issued a delayed certificate of marriage with that date. Schuett requested survivor benefits under the plan, but FedEx denied her claim, maintaining that Hall had not been legally married at the time of her death, and that even if she had been, Schuett did not meet the plan’s definition of spouse at the time. Schuett filed suit against FedEx, bringing numerous causes of action, including breach of fiduciary duty under ERISA. FedEx filed a motion for judgment on the pleadings.