Third Circuit Finds Release Agreement Bars Employee’s Lawsuit Seeking Additional Pension Benefits

In Miller v. Campbell Soup Company Retirement & Pension Plan Administrative Committee, No. 24-1812, 2025 WL 416090 (3d Cir. Feb. 6, 2025), the Third Circuit Court of Appeals considered Plaintiff-Appellant Sherry Miller’s appeal from a district court order finding that, due to an agreement she signed which released her ERISA claims, she is barred from bringing a misrepresentation claim in connection with her lawsuit for additional pension benefits. The court affirmed the decision of the district court.

The appeal arose from a dispute involving Miller’s entitlement to pension benefits following her retirement from Campbell Soup Company, where she had been employed for nearly three decades, interrupted by a brief break in service in 2001. Prior to her break, she accumulated benefits under a traditional pension formula; post-break, benefits accrued under a cash balance formula. Upon retiring in 2015, Miller signed a release agreement in exchange for severance pay and medical coverage, effectively releasing claims against Campbell Soup.

Miller later contended that the release did not encompass her claims for additional pension benefits, arguing that she was entitled to over 28 years of pension benefits instead of the 15 years acknowledged under the cash balance formula. Her legal claims included allegations of misrepresentation and equitable estoppel, asserting that Campbell Soup misrepresented the nature of her retirement benefits, thus breaching its fiduciary duty.

The district court, upon Appellee’s motion, dismissed Miller’s claim for additional benefits under the pension plan but permitted the misrepresentation and estoppel claims to advance. Subsequently, both parties filed motions for summary judgment. The district court ruled in favor of the Appellees, finding Miller’s claims barred by the release agreement she signed upon retirement. Miller’s motion for reconsideration was denied, prompting her appeal.

On appeal, Miller’s primary argument was that her claim for misrepresentation was not covered by the release, as the alleged misrepresentations were discovered post-release. She invoked the Third Circuit’s decision in Pell v. E.I. DuPont de Nemours & Co. Inc., seeking similar relief for her ERISA claim. However, the Third Circuit focused on whether the release agreement included the misrepresentation claims, rather than the merits of the claim itself.

The court explained that a claim for breach of fiduciary duty due to misrepresentation accrues when the employee relies detrimentally on the misrepresentations. In this case, the court determined that Miller’s claim accrued when she signed the release, not when she later discovered the alleged misrepresentations.

Miller also argued that the release did not apply to vested benefits under a qualified retirement plan. However, the court clarified that her claim was based on alleged misrepresentations rather than entitlement to vested benefits under the plan. The release explicitly encompassed claims of misrepresentation and equitable estoppel, further undermining Miller’s position.

The court also addressed Miller’s contention that she did not knowingly release the misrepresentation claim, asserting she was unaware of the claim at the time of signing. The court countered this by emphasizing the release’s language, which included all claims “that you have or may have,” thereby covering potential future claims discovered post-release.

Additionally, the court evaluated the consideration Miller received for signing the release. Despite Miller’s argument that the severance package offered was standard for similarly situated employees, the court found the consideration—101 weeks of salary and continued insurance coverage—substantial enough to support the release’s validity. The court noted that at the time of the release, there was no determination that Miller was entitled to damages exceeding the severance package.

In conclusion, the Third Circuit affirmed the District Court’s judgment, reiterating that the release agreement effectively barred Miller’s misrepresentation claims. The court’s decision underscores the importance of precise language in release agreements and the necessity for claimants to thoroughly understand the scope of claims being released. For practitioners, this case illustrates the critical role of clear drafting and the potential implications of release agreements in employment and ERISA-related disputes.