Fifth Circuit Affirms Dismissal of ERISA Breach of Fiduciary Duty Claim, Underscoring Plan Participants’ Duty to Inform Themselves of Plan Provisions

In LeBoeuf v. Entergy Corporation, et al., No. 24-30583, 2025 WL 1262414 (5th Cir. May 1, 2025), the Fifth Circuit Court of Appeals affirmed the district court’s dismissal of a breach of fiduciary duty claim under ERISA, brought by the Appellants, the children of decedent Alvin Martinez, against Entergy Corporation, its Employee Benefits Committee, and T. Rowe Price Trust Company.

Alvin Martinez, a former employee of Entergy Corporation, participated in a defined contribution pension plan governed by ERISA. In 2010, he designated his four children as beneficiaries. The plan stipulated that remarriage would revoke any prior beneficiary designation unless a new designation was made with spousal consent. Martinez remarried in 2014 but did not update his beneficiary designation or obtain spousal waiver consent from his new wife, Kathleen Mire. After Martinez’s death in 2021, the plan’s administrator directed the distribution of the plan’s assets to Mire, the surviving spouse, as per ERISA requirements.

Appellants initially sued Mire and the parties settled. They then pursued claims against Entergy, the Committee, and T. Rowe Price, alleging breach of fiduciary duty for failing to inform Martinez about the effects of his remarriage on the beneficiary designation. The district court dismissed these claims under Rule 12(b)(6), finding that neither Entergy nor T. Rowe Price were fiduciaries under ERISA, and that the Committee had not breached its fiduciary duties.

The Fifth Circuit evaluated whether Entergy and T. Rowe Price were fiduciaries. Under ERISA, fiduciary status is based on discretionary authority or control over plan management or assets. The court concluded that neither Entergy nor T. Rowe Price held such discretionary authority. Entergy’s alleged control over communication with plan participants was found to be conclusory and unsupported by factual evidence. Similarly, the court considered T. Rowe Price’s role in preparing and disseminating quarterly statements to be ministerial, not discretionary. The court cited 29 C.F.R. § 2509.75-8, which clarifies that performing administrative functions does not confer fiduciary status.

The Committee was uncontested as a fiduciary. However, the court found that Appellants failed to demonstrate that the Committee made material misrepresentations or failed to adequately inform Martinez. The court applied the Third Circuit’s framework, requiring proof of material misrepresentation or inadequate disclosure and detrimental reliance. The court noted that Martinez received multiple plan documents, including the Plan Document and beneficiary designation forms, all of which accurately detailed the impact of remarriage on beneficiary designations. Appellants’ reliance on quarterly statements, which did not restate this policy, was insufficient to establish a breach, particularly as Martinez never inquired about the policy despite receiving clear information elsewhere.

Appellants further argued that the quarterly statements misled Martinez by listing his children as beneficiaries. However, the court found no reasonable reliance on these statements in light of the clear language in formal plan documents. The court emphasized that plan participants have a duty to inform themselves of plan terms and that fiduciaries are not obligated to address participant misunderstandings absent an inquiry. In conclusion, the Fifth Circuit affirmed the district court’s dismissal, finding no fiduciary status for Entergy and T. Rowe Price and no breach by the Committee “because the Committee accurately disclosed the policy that marriage voids a plan member’s prior beneficiary designation unless a spousal waiver is executed.” The court underscored the importance of clear plan documentation and the participant’s responsibility to understand plan terms.