Can a Living Employee Sue Under ERISA When Termination Cuts Off Life Insurance Benefits? A Connecticut District Court Says No

In Martin v. Google LLC, No. 3:25-CV-587 (SVN), 2026 WL 3458571 (D. Conn. Nov. 13, 2026), the United States District Court for the District of Connecticut dismissed a terminated employee’s ERISA claims arising out of an employer-sponsored life insurance plan, while allowing his Americans with Disabilities Act claims to proceed. Plaintiff, a former Google sales representative, alleged that Google terminated him after he disclosed a Stage 4 colon cancer diagnosis, in part to avoid liability under his ERISA-covered life insurance plan. The court granted Google’s motion to dismiss the ERISA count under both Sections 502 and 510.

Why Did the ERISA Section 502(a)(1)(B) Claim Fail?

Section 502(a)(1)(B) lets a plan participant sue to recover benefits due under the terms of the plan. The court held that Plaintiff never alleged entitlement to any benefits under those terms. Plaintiff’s life insurance policy paid a death benefit to his spouse only if he died during employment, so the benefits would not vest until his death. The court found no factual basis for Plaintiff’s theory that he was owed some “vested percentage” of the benefits upon termination, because the complaint itself tied entitlement to his death. Plaintiff tried to recast the claim as one for “interference with the right to maintain coverage,” but he cited no authority recognizing that theory. His sole case, Sullivan-Mestecky v. Verizon Communications Inc., cut the other way, because the Second Circuit there held that the benefits never vested under the plan’s terms. Plaintiff’s counsel also conceded the Section 502 point at oral argument and confirmed that Plaintiff was pursuing only a Section 510 claim.

What Must a Plaintiff Show to State an ERISA Section 510 Claim?

Section 510 makes it unlawful to discharge a plan participant for the purpose of interfering with the attainment of any right under the plan. Citing Dister v. The Continental Group, Inc., the court explained that a Section 510 plaintiff must show the employer acted with the specific intent to interfere with ERISA rights, and that the loss of benefits amounted to more than a mere consequence of the termination. At the pleading stage, the court applied the lenient standard from Vega v. Hempstead Union Free School District, under which a plaintiff need only give plausible support to a minimal inference of discriminatory motivation rather than plead a full prima facie case.

Plaintiff’s allegations failed even that minimal standard. The court found that the complaint did not plausibly allege that Google appreciated the severity of his diagnosis. Although Plaintiff disclosed his Stage 4 colon cancer and asked about the accommodations process, he also alleged that he never missed a day of work, which undercut any inference that Google grasped how serious his condition was. The complaint did not allege that Plaintiff told his supervisors about his roughly 15% survival rate, pleading only that they knew or should have known. The court held that a “should have known” allegation cannot establish the specific intent Section 510 demands. The timing also worked against Plaintiff, because Google terminated him a full year after his disclosure and after he continued working through treatment. The court concluded that the unavailability of the life insurance benefits followed as a consequence of the termination, not as a motivating factor behind it, so the Section 510 claim could not stand.

What Happened to the ADA and State-Law Claims?

The court denied Google’s motion as to Plaintiff’s ADA disability discrimination and retaliation claims, finding his EEOC charge timely. Google argued the 300-day clock ran from the May 2024 notice of termination, but the court held that later emails reassigning Plaintiff to sales territories made that notice less than definite and that the July 31, 2024 termination plausibly stood as a distinct, final discriminatory act. The court dismissed Plaintiff’s common-law and state wage claims, including promissory estoppel, implied-in-fact contract, breach of the implied covenant, the Connecticut wage law claim, quantum meruit, unjust enrichment, and negligent misrepresentation. An integrated written compensation agreement governed Plaintiff’s pay, the parol evidence rule barred the alleged oral promise of a more lucrative commission plan, and an express contract foreclosed the implied and quasi-contract theories. The court denied leave to amend the dismissed counts.