Fifth Circuit Cements Victory to AT&T in ERISA Dispute Seeking Statutory Penalties for Failing to Produce Documents

In Jones, IV, as executor & administrator of The Succession of Connie Porter Jones Marable v. AT&T, Inc., et al., No. 24-30187, 2025 WL 720939 (5th Cir. Mar. 6, 2025), the Fifth Circuit Court of Appeals reviewed the district court’s decision concerning whether AT&T owed discretionary penalties under ERISA for allegedly failing to provide required plan documents. Plaintiff-Appellant, William Jones, argued that AT&T did not comply with 29 U.S.C. § 1024(b)(4) and sought penalties under 29 U.S.C. § 1132(c)(1). The court’s analysis focused on three primary legal issues: discovery rulings, denial of a motion to amend, and the imposition of civil penalties.

First, regarding discovery, the court affirmed the district court’s decision to limit the scope of discovery. The Magistrate Judge had denied parts of Jones’s motion to compel discovery, citing irrelevance and disproportionality to the narrow issue at hand—whether AT&T complied with § 1024(b)(4). The district court found no clear error in this ruling, emphasizing that Jones already possessed relevant documents from prior litigation. The Fifth Circuit agreed, noting that discovery rulings are overturned only when arbitrary or clearly unreasonable, and that the district court did not abuse its wide discretion.

Second, on the issue of amending the complaint, the court upheld the district court’s denial of Jones’s motion for leave to amend. The motion was filed fifteen months post-suit initiation and nine months after the deadline for amendments. The proposed amendments sought to introduce new claims, including breach of fiduciary duty. Under Federal Rule of Civil Procedure 16(b), amendments after a scheduling order require a showing of good cause. The court considered factors such as the timing, importance, and potential prejudice of the amendment, concluding that Jones failed to demonstrate good cause, partly because he inadequately briefed the issue on appeal.

Third, concerning the imposition of penalties, the court examined whether AT&T’s failure to provide certain documents warranted penalties under § 1132(c)(1). The district court found that AT&T did not act in bad faith or with intent to withhold documents and exercised reasonable care in their document production. Additionally, the court determined that Jones was not prejudiced by any alleged failures, as he had access to relevant grievance procedures and chose not to use them. The Fifth Circuit affirmed these conclusions, emphasizing that penalties are discretionary and not mandatory, even in cases of technical violations, especially absent bad faith or prejudice.

Overall, the Fifth Circuit affirmed the district court’s judgment in favor of AT&T, concluding that there was no abuse of discretion in the district court’s rulings on discovery, amendment of the complaint, or denial of penalties.