Western District of Washington Dismisses ERISA Claims Challenging Aviation Exclusion in AD&D Policy

In Aloff v. The Prudential Insurance Company of America et al., No. 3:25-CV-05834-DGE, 2026 WL 445565 (W.D. Wash. Feb. 17, 2026), the U.S. District Court for the Western District of Washington dismissed beneficiaries’ ERISA claims seeking accidental death and dismemberment (AD&D) benefits after a fatal plane crash, holding that the plaintiffs failed to identify specific plan terms entitling them to benefits and that their related fiduciary-duty and state-law claims could not survive dismissal.

Background

The plaintiffs were the widows and designated beneficiaries of two pilots employed by Clay Lacy Aviation, Inc., who died in a February 2024 airplane crash. They sought AD&D benefits under a group life insurance policy funded and administered by Prudential and governed by ERISA. Prudential denied the claims and upheld the denials on appeal, citing an “aviation exclusion.”

The plaintiffs alleged that the aviation exclusion either did not apply or should be stricken as contrary to public policy, arguing that an aviation employer should not be permitted to provide life insurance coverage that excludes aviation-related deaths for pilots. They also asserted that the employer’s representation that it offered fully paid life insurance was misleading in light of the exclusion.

The complaint asserted five causes of action:

1. Recovery of benefits under ERISA § 502(a)(1)(B);
2. Breach of fiduciary duty;
3. Equitable relief under ERISA;
4. Violation of California’s Unfair Competition Law (UCL); and
5. Violation of Washington’s Consumer Protection Act (WCPA).

Failure to State a Claim for Benefits

The court dismissed the § 502(a)(1)(B) claim because the plaintiffs failed to identify specific plan terms entitling them to AD&D benefits. Although they challenged the applicability and validity of the aviation exclusion, they did not allege the actual plan provisions that conferred coverage or explain how the terms supported their entitlement to benefits. As the court emphasized, a claim for benefits “stands or falls by the terms of the plan,” and plaintiffs must identify the plan language that provides the benefit at issue.

The court also dismissed the claim against the employer, Clay Lacy, because the complaint did not allege that the employer exercised discretionary authority over benefit determinations or otherwise qualified as a proper defendant under § 502(a)(1)(B).

Fiduciary Duty Claims

The court held that the plaintiffs plausibly alleged Prudential acted as an ERISA fiduciary because it processed claims, interpreted the policy, and decided appeals—functions that involve discretionary authority.

However, the court dismissed the fiduciary-duty claims because they were premised on the same theory as the deficient benefits claim—namely, that defendants wrongfully failed to pay AD&D benefits. Without adequately pleading entitlement to benefits under the plan’s terms, the plaintiffs could not sustain a claim that the failure to pay those benefits constituted a breach of fiduciary duty.

The court dismissed the fiduciary claims against the employer as well, finding no factual allegations supporting fiduciary status.

ERISA Preemption of State Law Claims

The court dismissed the UCL and WCPA claims with prejudice, holding they were expressly preempted by ERISA. The plaintiffs’ state-law theories were based on alleged violations of ERISA and sought recovery of insurance benefits under the plan. Because the claims were premised on the existence of the ERISA plan and sought to secure plan benefits through alternative legal theories, they were preempted.

Leave to Amend

Although the complaint was dismissed in its entirety, the court granted leave to amend the ERISA claims, noting that this was the first ruling on the sufficiency of the pleading and that the deficiencies might be cured through more specific factual allegations.