ERISA Fiduciary Obligations: More on Application to Life Insurance Coverage

This article examines the case of Biller v. Prudential Insurance, in which the U.S. District Court for the Northern District of Georgia denied a motion to dismiss a claim brought against an employer by the beneficiaries of a deceased employee who had sought to convert her group life insurance coverage to individual coverage upon her termination of employment. Despite timely repeated requests, the employer failed to provide the employee with the form necessary for conversion of the policy until after the specified deadline such that the insurer denied the conversion request. The court upheld the plaintiffs‟ right to pursue an action against the employer under ERISA for breach of its fiduciary duty under the group life plan and to seek monetary damages as an equitable remedy.