Fifth Circuit Affirms Denial of Deceased Ex-Spouse’s Retirement Benefits

In Chetlin v. Exxon Mobil Oil Corporation, No. 20-20641, __F.App’x__, 2021 WL 2492771 (5th Cir. June 17, 2021), Plaintiff-Appellant Medora Chetlin filed suit under ERISA against Defendant Exxon Mobil Oil Corporation (“Exxon”) after it denied her claim for her deceased ex-husband’s retirement benefits. Her husband died before his retirement date and there was no Qualified Domestic Relations Order in place that would have provided her with a benefit. The district court granted summary judgment in favor of Exxon and the Fifth Circuit affirmed.

Chetlin and her ex-spouse, Nathan Broussard, were married at the time he started working for Exxon in 1968 but they divorced in 1974 and he stopped working for Exxon in 1982. As part of the divorce proceedings, Chetlin was awarded a community property interest in Broussard’s retirement plan with Exxon. Broussard was entitled to a straight life annuity after his calculated retirement date of January 1, 2008, but he passed away in February 2007. The plan provided that his designated beneficiary, Chetlin, would receive a refund of his $280.68 contribution plus interest. In November 2012, Exxon wrote to Chetlin informing her she was eligible for a refund. She twice requested information about Broussard’s contributions but did not receive an immediate response. Then in August 2013, Exxon requested that Chetline complete and return a form for the refund and provide Broussard’s death certificate. After no communication for six years, Chetlin filed suit in state court against Exxon, which Exxon removed to federal court. Exxon then wrote to Chetlin denying her request for benefits exceeding those identified in its November 2012 letter and explaining that because Broussard was divorced as of the date of his death and there was no QDRO in place, she would not be entitled to a benefit such as an annuity. The letter advised Chetlin of her right to appeal but she did not do so.

Exxon moved for summary judgment on the basis that it was not the proper defendant, that Chetlin did not exhaust her administrative remedies, and that its denial was supported by the record and the terms of the plan. The magistrate judge issued a memorandum and recommendation to the district judge concluding that (1) Exxon was not the proper defendant and Chetlin’s claims against it could be dismissed on that basis; (2) because it took seven years for Exxon to provide Chetlin with the information and documents she sought from the retirement plan and she had no other way to obtain the information needed to make a formal claim for benefits, she was excused on equitable grounds for failure to exhaust her administrative remedies; and (3) Exxon’s determination that Chetlin was limited to a refund of Broussard’s contribution plus interest was supported by the administrative record and the terms of the retirement plan.” The district court adopted the recommendations but declined to decide whether Exxon was the proper defendant because it was not the only determinative issue in the proceedings.

The Fifth Circuit agreed with the reasoning of the district court for declining to hold whether Exxon was the proper defendant. The court also agreed that the benefits decision was correct and supported by the administrative record. Chetlin argued the record was likely incomplete but failed to present evidence negating its accuracy. Exxon provided Chetlin with an explanation of benefits and a copy of the retirement plan. The court concluded that the district court did not err in granting summary judgment in favor of Exxon.