Mays-Williams v. Williams

Under the Employee Retirement Income Security Act, a plan participant must substantially comply with governing plan documents when requesting a change in beneficiary designation.

Asa Williams, Senior (“Asa, Senior”) and Carmen Mays-Williams (“Carmen”) were married in 1993, and in 2002, Asa, Senior designated Carmen as the beneficiary of his employee benefits plans. In 2004, Asa, Senior retired after thirty years with Xerox, being eligible for benefits under two separate plans, which were both subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). In 2006, Carmen and Asa, Senior divorced. Asa, Senior attempted to change his beneficiary designation to his son from a previous marriage, Asa Williams, Junior (“Asa, Junior”) via multiple telephone conversations with Xerox. After each conversation, Asa, Senior received beneficiary designation forms to confirm the change in beneficiary from Xerox, but he did not sign or return the forms. In 2011, Asa, Senior died, and both Carmen and Asa, Junior asserted claims as the plan beneficiary. Xerox interpleaded both parties in district court for a determination of the proper beneficiary. The district court granted a motion for summary judgment in favor of Carmen. On appeal, the Ninth Circuit held that a plan participant must substantially comply with governing plan documents when requesting a change in beneficiary designation. The governing plan documents required married participants to submit a written designation in order to change a beneficiary designation, but were silent as to whether unmarried participants could change a beneficiary designation by telephone. The panel found that Asa, Senior substantially complied with the requirement to change the designation, and, therefore, there was a triable issue of fact. REVERSED and REMANDED.