District of Utah Confirms Only Named Plan Administrator May Face § 1132(c) Penalties

In Mayor v. Metro. Life Ins. Co., itself & as administrator of Union Pac. Corp. Nonagreement Life Ins. Plan 0149653, et al., No. 1:25-CV-00012-DBB-DAO, 2025 WL 3251356 (D. Utah Nov. 21, 2025), the District of Utah addressed whether a claims administrator may be held liable for statutory penalties under ERISA § 1132(c) for failing to provide plan documents. The court reaffirmed the Tenth Circuit’s strict interpretation of § 1132(c), holding that only the designated plan administrator—as named in the governing plan documents—can be subject to penalties. Because the complaint identified Union Pacific officers as the plan administrators, and MetLife acted only as a claims administrator and alleged agent, the court dismissed the § 1132(c) claim against MetLife.

Background

Nicole Mayor sought life and accidental death benefits as the beneficiary of her late husband’s Union Pacific–sponsored life and AD&D coverage. After MetLife denied the AD&D claim based on a policy exclusion, she requested plan documents from both MetLife and Union Pacific’s HR department. She alleges that neither provided her with the governing policy.

Mayor sued under ERISA, asserting (1) failure to provide plan documents under 29 U.S.C. § 1132(c) and (2) wrongful denial of benefits. MetLife moved to dismiss the § 1132(c) claim.

Issue

Can MetLife—acting as a claims administrator and alleged agent of the plan administrator—be held liable for statutory penalties under § 1132(c) for failing to provide plan documents?

Court’s Analysis

1. Only the plan administrator is liable under § 1132(c).

The court reaffirmed well-established Tenth Circuit precedent that:

• § 1132(c) authorizes penalties only against the “administrator” designated in the plan documents.
• The Tenth Circuit does not recognize “de facto” administrators.
• Agency principles do not expand statutory liability to an administrator’s agents; liability remains solely with the named administrator.

2. Plaintiff’s own allegations identified Union Pacific officers—not MetLife—as the plan administrator.

Mayor’s complaint explicitly alleges:

• Union Pacific executives Whited and Perkes served as plan administrators.
• MetLife acted only as an agent that allegedly agreed to pay penalties on the administrator’s behalf.

The court held that—even accepting all allegations as true—MetLife cannot be liable under § 1132(c).

3. “Agency” theory cannot create statutory liability.

Even if MetLife handled document requests as the plan administrator’s agent, the statute does not impose penalties on agents. At most, an agent’s misconduct may be imputed to the plan administrator—not the other way around.

Holding

The court granted MetLife’s motion to dismiss the § 1132(c) document-penalty claim.
The benefits-denial claim remains pending.

Key Takeaway for ERISA Practitioners

This decision reinforces the Tenth Circuit’s strict approach to § 1132(c):

• Only the entity formally designated in plan documents as the “plan administrator” may be sued for document penalties.
• Claims administrators—no matter how involved in day-to-day operations—are not liable, and plaintiffs cannot use agency theories or alleged contractual arrangements to impose § 1132(c) penalties on them.

This case serves as another reminder to scrutinize plan documents early: the identity of the named administrator is dispositive for § 1132(c) claims.