What Happens When an ERISA Plan Administrator Ignores Your Request for Documents?

In Haldeman v. Mass General Brigham Inc., No. 25-cv-10331-ADB, 2026 WL 2687259 (D. Mass. Sept. 14, 2026), a federal court in Massachusetts awarded a $5,000 statutory penalty against an ERISA plan administrator that took 230 days to provide plan documents a participant had requested to prepare her long-term disability appeal.

Who Is the Proper Defendant Under ERISA’s Document-Disclosure Rules?

Plaintiff participated in the Massachusetts General Hospital Long Term Disability Wrap Plan and sued both the Plan and Mass General Brigham, Inc. (MGB), the Plan’s administrator, after a claim administrator denied her long-term disability benefits and her repeated requests for the governing plan documents went unanswered. The court held that only MGB was a proper defendant. Under ERISA, the plan administrator is a defined term distinct from the plan itself, and only the administrator can face penalties under 29 U.S.C. § 1132(c)(1). The court therefore granted summary judgment to the Plan and allowed the case to proceed against MGB alone.

When Does an ERISA Administrator “Fail to Comply” With a Document Request?

Plaintiff’s counsel first requested the plan documents on September 18, 2024, in connection with a planned appeal, then followed up repeatedly over the next several months. MGB acknowledged the requests, promised more than once to send the documents promptly, and did not do so. It produced the documents for the first time on May 6, 2025, 230 days after the initial request. MGB argued that Plaintiff’s counsel already possessed the documents from separate matters involving other plan participants, but the court rejected that defense. MGB never told counsel she already had the documents until the day it finally produced them, and its own statements, including a comment about needing to confirm the most up-to-date version, invited counsel not to rely on materials produced for other clients. The court held that MGB failed to timely provide the plan documents in response to a proper request under § 1132(c)(1).

Can a Court Award Penalties Without a Finding of Bad Faith?

Yes. The court explained that prejudice and bad faith are not prerequisites for a penalty and that courts weigh the totality of the circumstances, with deterrence as a central purpose. Plaintiff did not allege bad faith, but the court found that MGB’s pattern of promising prompt production and then failing to deliver reflected a disregard of its statutory obligations. The court also found sufficient prejudice: ERISA’s scheme is built around a participant’s reliance on the written plan documents, and Plaintiff was deprived of those documents while planning her appeal, which the court held is inherently prejudicial regardless of the appeal’s outcome. The statutory maximum of $110 per day operates as a ceiling rather than a required rate, and the total is left to the court’s discretion. Weighing these factors, the court imposed a $5,000 penalty.

Does Winning a Penalty Entitle a Participant to Attorney’s Fees?

The court held that Plaintiff’s successful penalty claim established more than trivial or purely procedural success and entitled her to attorney’s fees and costs. Applying the governing multi-factor analysis, the court found the factors favored an award: MGB made little effort to comply despite repeated reminders, there was no suggestion it could not pay, an award would deter similarly situated administrators, the suit secured documents Plaintiff needed to litigate her appeal, and MGB’s position rested largely on a retrospective justification with little merit. The court ordered MGB to pay the $5,000 penalty plus reasonable attorney’s fees and costs and directed Plaintiff to move for fees within fourteen days.