District of Connecticut Dismisses ERISA § 510 Claim Against Google, Holding Plaintiff Failed to Plausibly Allege Termination Intended to Prevent ERISA Benefits

In Martin v. Google LLC, No. 3:25-CV-587 (SVN), 2026 WL 657265 (D. Conn. Mar. 9, 2026), the U.S. District Court for the District of Connecticut dismissed a former Google sales representative’s ERISA § 510 interference claim and several related state-law claims, holding that the complaint failed to plausibly allege that Google terminated the employee with the specific intent to interfere with ERISA-protected benefits.

Background of the Dispute

The plaintiff worked as an Enterprise Field Sales Representative in Google’s cloud division. His compensation was governed by internal sales incentive plans that varied depending on the type of accounts handled. Representatives assigned to existing customers were compensated under a “Spender” plan, while representatives responsible for bringing in new customers were compensated under a “Greenfield” plan that allowed for significantly higher commissions.

In 2023, Google converted the plaintiff to the Spender plan. According to the complaint, however, he had already been pursuing a large potential contract with Otis Elevator valued at approximately $35 million. The plaintiff alleged that his supervisors verbally authorized an “exception” allowing him to continue pursuing that deal under the Greenfield compensation structure. The plaintiff asked that the agreement be put in writing, but the request was declined.

The plaintiff ultimately secured the Otis contract in December 2023. When he sought commissions for the deal, however, he was informed that the alleged exception only allowed him to pursue the account, not to receive Greenfield commissions for it. The plaintiff claimed he was owed at least $2 million in commissions.

Around this same period, the plaintiff disclosed to Google that he had been diagnosed with Stage 4 colon cancer and had begun chemotherapy treatment. Although he alleged that he continued to perform his job and meet professional commitments, he claimed that Google subsequently reassigned many of his accounts, gave him a lower performance review, and ultimately terminated his role in mid-2024 as part of a reduction in force. Because his employment ended, his ERISA-covered life insurance benefits—allegedly totaling nearly $4 million—were cancelled.

ERISA § 510 Interference Claim

The plaintiff asserted that Google violated ERISA § 510 by terminating him to interfere with his attainment of benefits under the company’s life insurance plan. Section 510 prohibits employers from discharging an employee for the purpose of preventing the employee from obtaining benefits under an ERISA plan.

The court concluded that the complaint did not plausibly allege the required intent. To state a claim under § 510, a plaintiff must show that interference with ERISA benefits was at least part of the employer’s motivation for the termination. It is not enough that termination resulted in the loss of benefits as a consequence.

According to the court, the allegations suggested that Google may have terminated the plaintiff because of his cancer diagnosis or because of disputes concerning commissions. But those allegations did not plausibly establish that the company acted with the specific purpose of preventing him from obtaining ERISA benefits. At most, the complaint alleged that the loss of benefits followed from the termination.

The court also observed that other allegations in the complaint undermined the plaintiff’s theory that Google acted to avoid life-insurance liability. For example, the complaint described the plaintiff as continuing to work actively during treatment and even traveling internationally for work. These allegations made it less plausible that Google believed a life-insurance payout was imminent and therefore terminated him to avoid potential liability under the policy.

Because the complaint relied primarily on conclusory assertions that the termination was designed to avoid ERISA obligations, the court held that the § 510 claim was insufficiently pleaded and dismissed it.

State Law Claims

The court also dismissed the plaintiff’s state-law claims for breach of contract, unpaid wages under Connecticut law, unjust enrichment, and fraudulent inducement.

The court found that the breach-of-contract claim failed because the written compensation plan governing the plaintiff’s role did not entitle him to commissions on the Otis deal. The plaintiff relied instead on the alleged oral agreement allowing him to be compensated under the Greenfield plan. The court held that this allegation was barred by the parol evidence rule because it sought to modify the written terms of the Spender plan that governed the plaintiff’s compensation.

The court found that the statutory wage claim failed for the same reason. Under Connecticut law, the wage statute merely provides a mechanism to recover wages owed under an agreement between the employer and employee. Because the plaintiff had not plausibly alleged a contractual entitlement to the commissions, the wage claim could not proceed.

The court also dismissed the unjust enrichment claim because the plaintiff pleaded in a way that incorporated the allegations of an express contractual relationship between the parties. Under Connecticut law, unjust enrichment is generally unavailable when the dispute arises from a contract governing the parties’ relationship.

Finally, the court dismissed the fraudulent inducement claim. Although the complaint identified the alleged statements and speakers with sufficient specificity, it did not include factual allegations supporting the claim that Google’s representatives knew their statements were false when made. The court also concluded that the claim was duplicative of the breach-of-contract theory because the alleged misrepresentation concerned the same compensation terms at issue in the contract dispute.

The court granted Google’s motion to dismiss in full. However, it allowed the plaintiff an opportunity to amend his complaint as to most of the claims, while concluding that amendment of the fraudulent inducement claim would be futile.