Third Circuit Affirms Dismissal of Life Insurance Claim Against Employer-Plan Administrator, Holding Only the Entity Controlling Benefit Determinations Is a Proper Defendant Under ERISA

In Justman v. Accenture LLP, — F.4th —-, No. 25-2084, 2026 WL 1742110 (3d Cir. June 17, 2026), Plaintiff Justman, individually and as executor of the estate of his late wife, sued his wife’s employer, Accenture LLP, for the denial of accidental life insurance and AD&D benefits under an ERISA-governed plan. The decedent died of septic shock caused by vibrio vulnificus bacterium after eating raw oysters. Prudential Insurance Company of America, the Claims Administrator, denied the claim on the ground that the decedent died of a medical illness or sickness rather than as the direct result of an accident. Prudential settled out of the case, leaving only the claims against Accenture. The District Court for the Eastern District of Pennsylvania dismissed Plaintiff’s Second Amended Complaint with prejudice, and the Third Circuit affirmed.

The court held that Accenture was not a proper defendant for Plaintiff’s wrongful denial of benefits claim under ERISA § 502(a)(1)(B). The court explained that a suit for benefits due must be brought against a party with an obligation to pay, which is the entity that controls benefit determinations. Here, the plan and the summary plan descriptions consistently identified Prudential as the Claims Administrator with discretionary authority to process and decide claims, while Accenture, as Plan Administrator, retained authority only over limited matters such as eligibility. The court rejected Plaintiff’s reliance on SPD language stating that benefits would be paid only if the Plan Administrator and/or Claims Administrator decided the claimant was entitled to them, noting that under CIGNA Corp. v. Amara, SPDs do not themselves constitute the terms of the plan. The court further found that a letter from Prudential to Accenture noting the denial and offering a phone number for questions confirmed that Prudential, not Accenture, made the benefits determination. In so holding, the court aligned itself with five other circuits and noted the consistent reasoning of two more.

The court also rejected Plaintiff’s SPD claim. Whether construed as a failure to furnish required plan documents under ERISA § 104(b)(1) or a breach of fiduciary duty claim under ERISA § 404, the Second Amended Complaint failed to state a claim. Plaintiff did not plead facts establishing when any SPD was due, and even assuming the 2021 change from MetLife to Prudential was a material modification, an updated SPD would not have been due until July 2022, after the decedent’s death in August 2021. The breach of fiduciary duty claim failed because Plaintiff did not allege that the failure to provide the SPDs deprived the decedent of material information or that anyone relied on the SPDs in the claim dispute with Prudential. The court concluded that further amendment would be futile and affirmed the District Court’s orders denying leave to file a Second Amended Complaint, denying reconsideration, and dismissing the case with prejudice.