D.C. Circuit Affirms Denial of Post-Judgment Discovery Where Plaintiff Failed to Raise “Significant Questions” About ERISA Injunction Compliance

In Kifafi v. Hilton Hotels Retirement Plan, et al., No. 25-7053, 2026 WL 125263 (D.C. Cir. Jan. 16, 2026), the D.C. Circuit affirmed a district court’s denial of a class representative’s request for broad post-judgment discovery and an equitable accounting aimed at monitoring compliance with a long-standing ERISA injunction.

The case has a lengthy procedural history. In earlier proceedings, the district court found that Hilton violated ERISA’s anti-backloading and vesting provisions and entered a permanent injunction requiring remedial action, which the D.C. Circuit previously affirmed. Although the district court later terminated its active supervision of the injunction after finding Hilton in compliance, the D.C. Circuit clarified in a 2022 decision that the injunction remained enforceable and that courts retain authority to ensure compliance if implementation breaks down.

On remand, the plaintiff sought expansive post-judgment discovery and an equitable accounting, requesting years of communications, participant-level records, and documents related to Hilton’s compliance efforts. The district court denied the motion without prejudice, concluding that the plaintiff had not raised “significant questions” suggesting noncompliance that would justify such intrusive discovery.

The D.C. Circuit affirmed. Applying an abuse-of-discretion standard, the court held that the district court properly used the “significant questions” framework and reasonably concluded that the plaintiff failed to meet that threshold based on the evidence presented. The court also rejected the argument that the district court erred by not separately addressing equitable accounting, noting that the plaintiff treated accounting as effectively indistinguishable from broad post-judgment discovery and offered no independent justification for it.

Importantly, the court reiterated that federal courts retain power to enforce ERISA injunctions and that plan fiduciaries remain subject to ongoing obligations. At the same time, the court emphasized limits on enforcement mechanisms, explaining that expansive discovery is not warranted absent concrete indications of noncompliance. While the panel acknowledged that more tailored requests for discrete compliance information—such as identifying unpaid participants and explaining payment delays—may be appropriate in some circumstances, it declined to decide whether such relief would be required on a different record. Judgment affirmed.