When Dependent Life Coverage Ends at Divorce: Court Dismisses ERISA Benefits and Fiduciary-Breach Claims Despite an Employer’s Admitted Mistake

In Wright v. Hartford Life and Accident Insurance Company, No. 3:25-CV-297-CHB, 2026 WL 2925146 (W.D. Ky. Sept. 29, 2026), a Kentucky federal court granted motions to dismiss both the ERISA benefits claim and the breach-of-fiduciary-duty claim brought by a plan participant who continued paying premiums on a dependent life insurance policy covering her former husband after their divorce. The decision is a reminder that under plan and policy language tying coverage to spousal status, divorce can end coverage regardless of continued premium deductions, and that an employer’s erroneous benefits advice does not, without more, support equitable relief under ERISA.

How did a dependent life claim end up in federal court?

Plaintiff elected dependent life insurance covering her husband under her employer’s ERISA-governed health and welfare benefit plan, naming herself as beneficiary. The coverage was insured through a group policy issued by Hartford Life. After a decree dissolving the marriage was entered, Plaintiff contacted her employer’s human resources office to ask what she needed to do about her benefits. She was directed to a benefits phone number, and when she called, she was told she could not stop the dependent life elections, that premiums would continue to be deducted until the next open enrollment in November 2024, and that the coverage would remain in force until then. Plaintiff continued making premium payments by payroll deduction.

Her former husband died in July 2024. When Plaintiff sought to initiate a claim, she was told it would be denied. The employer later refunded the premium payments through her paycheck, and in a meeting a human resources officer acknowledged that a mistake had been made regarding the information provided to Plaintiff, while reiterating that the claim would be denied. Hartford Life denied the claim and the subsequent appeal, explaining that the couple was divorced at the time of death, so the decedent no longer met the policy’s definition of Spouse and was not eligible for coverage.

Plaintiff then filed suit, bringing a claim to recover benefits under 29 U.S.C. § 1132(a)(1)(B) against Hartford Life and the Plan, and a claim for breach of fiduciary duty and other equitable relief under 29 U.S.C. § 1132(a)(3) against the employer-affiliated defendants.

Can an ERISA benefits claim be dismissed at the pleading stage?

The court first rejected Plaintiff’s argument that ERISA denial-of-benefits claims are categorically inappropriate for resolution on a Rule 12(b)(6) motion. Plaintiff cited no authority for that position, and the court noted that the defendants were not seeking judgment on the administrative record but rather arguing that the complaint failed to state a claim on its face. Plaintiff also identified no additional information in any administrative record that could change the outcome. Because the Plan and Policy documents were referenced in the complaint and central to the claims, the court considered those documents in ruling on the motions.

Why did the court dismiss the benefits claim?

Turning to the policy language, the court explained that coverage for a dependent ends on the date the dependent no longer meets the definition of Dependent, unless coverage is continued under the policy’s Continuation Provisions. The policy defined Spouse as a spouse who is not legally separated or divorced from the employee. Under that plain language, the court held, coverage for the former husband terminated upon divorce unless a Continuation Provision applied.

Plaintiff did not dispute that coverage would otherwise have terminated at divorce. She argued instead that a plan of continuation applied, but she did not rely on any of the leave-based Continuation Provisions actually listed in the policy. Instead, she pointed to Section 5.8 of the 2024 Plan, titled “Changing Elections,” which allows an employee to revoke an election on account of a Change in Status, including divorce. Plaintiff reasoned that because she had the option but not the obligation to revoke her election, the coverage remained in place until open enrollment.

The court found that reading unpersuasive. Section 5.8 governs when an employee may make or change elections, and it provides an exception to the general rule that elections change only during annual enrollment. As the defendants argued, the Change-in-Status exception is tied to gaining or losing eligibility, and the subsection required that any election change be consistent with the Change in Status. Whether or not Plaintiff formally revoked the election, her eligibility for the benefit was governed by the policy, which terminated spousal coverage at divorce.

The court also rejected Plaintiff’s reliance on Section 3.3 and the Plan’s general eligibility provisions. Section 3 addresses an employee’s eligibility to participate in the Plan, not eligibility to receive a specific elected benefit. Section 3.1 expressly directed that specific eligibility requirements for particular benefits are set forth in the applicable Incorporated Documents, which included the Policy. Because the policy unambiguously terminated spousal coverage at divorce, and because Section 5.8 was not a “plan of continuation which applies to all employees the same way,” the court held that Plaintiff’s proposed interpretation was not reasonable and dismissed Count I against both Hartford Life and the Plan.

What equitable remedies did the court reject under Section 1132(a)(3)?

On the breach-of-fiduciary-duty claim, the court did not resolve whether the benefits-hotline advice was given in a fiduciary capacity or whether Plaintiff relied on it. It dismissed Count II on the narrower ground that Plaintiff failed to allege entitlement to any available form of equitable relief, considering each remedy she identified.

On surcharge, the court held that the remedy is unavailable, relying on Aldridge v. Regions Bank, 144 F.4th 828 (6th Cir. 2025), which held that § 1132(a)(3) does not permit plan participants to seek monetary relief from fiduciaries for losses caused by a breach of duty. The court treated Aldridge as binding and noted that Plaintiff offered no explanation for how her request for surcharge was anything other than a request for money damages.

On estoppel, because the Plan’s terms were unambiguous, the court applied the eight-element ERISA-estoppel test drawn from Sprague v. General Motors Corp., Bloemker v. Laborers’ Local 265 Pension Fund, and Higgins v. Lincoln Electric Co. The court found Plaintiff failed to plead several essential elements, including the defendants’ awareness of the true facts coupled with intended deception or gross negligence amounting to constructive fraud, the defendants’ intent that she rely on the misstatement, and extraordinary circumstances such as affirmative misconduct or repeated assurances capable of overriding unambiguous plan language.

On reformation, the court explained that the remedy requires either mutual mistake or a situation where one party is mistaken and the other commits fraud or inequitable conduct, citing Pearce v. Chrysler Group LLC Pension Plan. Plaintiff alleged at most that a benefits agent gave her incorrect information. She did not allege that she lacked access to the Plan documents or that she investigated her benefits and drew a reasonable conclusion based on a misrepresentation. Her allegation of a unilateral mistake inconsistent with the written plan did not support reformation.

On unjust enrichment, which the court construed as a request for equitable restitution, the court held that Plaintiff failed to identify specific traceable funds in the defendants’ possession, as Great-West Life & Annuity Insurance Co. v. Knudson requires. Plaintiff had already been fully refunded the premiums she paid, and her general allegations that those premiums could be traced to Plan assets did not establish an equitable interest in any particular property.

Finding that the relief Plaintiff sought was not an available form of equitable relief, the court dismissed Count II against the employer-affiliated defendants and granted both motions to dismiss.