District of Puerto Rico Dismisses ERISA Claims Against Home Depot Based on Prior Settlement Agreement

In Llanos-Torres v. The Home Depot Puerto Rico, Inc., et al., No. CV 24-01058 (MAJ), 2025 WL 2712432 (D.P.R. Sept. 23, 2025), the District Court for the District of Puerto Rico granted Home Depot’s motion to dismiss, holding that the plaintiff’s ERISA claims against certain defendants were both improperly pled and barred by a prior settlement agreement.

Plaintiff, a former Home Depot employee, originally filed suit in Puerto Rico court in January 2024 seeking disability benefits. The case was removed to federal court under ERISA. Over the course of multiple amended complaints, Plaintiff added several defendants, including Home Depot Puerto Rico, Home Depot USA, the Home Depot Welfare and Group Benefit Plans, the Administrative Committee, and Scott Smith as its sole member, in addition to Aetna and The Hartford.

The Court had already dismissed Home Depot entities once before, finding they were not proper defendants under ERISA § 502(a)(1)(B), which limits liability to entities that actually control plan administration. Despite these prior rulings, Plaintiff’s Second Amended Complaint again included Home Depot entities and new fiduciary duty claims under ERISA §§ 502(a)(2) and (3).

The Court reaffirmed its earlier conclusion that Home Depot Puerto Rico, Home Depot USA, the Administrative Committee, and Smith were not proper defendants to Plaintiff’s § 502(a)(1)(B) benefits claim because they had no authority to review or decide disability benefit claims. That authority rested with Aetna and The Hartford.

As to the fiduciary duty claims, the Court held they were barred by a Settlement Agreement and General Release Plaintiff executed in October 2022. In that agreement, Plaintiff broadly released Home Depot and its affiliates from all employment-related and ERISA claims arising from events before the agreement’s execution. The only exceptions were for COBRA rights, certain benefits claims under § 502(a)(1)(B), enforcement of the settlement’s own terms, and claims that cannot legally be waived. Because the fiduciary duty claims arose from events that occurred well before October 2022, they fell squarely within the scope of the release.

The Court rejected Plaintiff’s argument that the claims fell under the settlement’s exceptions. While she attempted to frame them as post-settlement fiduciary breaches, the allegations all traced back to her 2017 employment termination, the 2020 plan merger, or her 2020 disability claim filings. None involved new post-settlement conduct.

The decision underscores two important principles in ERISA litigation:

1. Proper Defendant Requirement – Only entities with actual control over plan administration may be sued for benefits under ERISA § 502(a)(1)(B).
2. Settlement Agreements Matter – A broad release will bar later attempts to repackage old claims as new fiduciary breaches unless clear post-settlement conduct is alleged.

The Court dismissed with prejudice all claims against Home Depot Puerto Rico, Home Depot USA, the Administrative Committee, and Scott Smith.