Labor & Employment Law Daily Wrap Up, PENSION AND BENEFIT PLANS—3d Cir.: Employer lacking authority over benefit determinations cannot be sued for denial of benefits, (Jun 18, 2026)

By Ronald Miller, J.D.

Accenture was not a proper defendant for the husband’s denial of benefits claim, and the district court was right to dismiss this claim.

An employer that lacked authority over benefit determinations may not be sued for denial of benefits under ERISA, ruled the Third Circuit. After an Accenture employee died, her husband sought accidental death benefits, but the claims administrator, Prudential, denied his claim. He sued Accenture, the plan administrator, and Prudential. Prudential settled with the husband. Thereafter, the district court dismissed the husband’s denial of benefits claim. Because Accenture delegated claims administration duties to Prudential, it did not control benefit determinations, ruled the appeals court. Rather, Prudential was the proper defendant for the husband’s denial of benefits claim. Accordingly, the husband had no denial of benefits claim, and the Third Circuit affirmed dismissal of his claims (Justman v. Accenture LLP, No. 25-2084 (3d Cir. June 17, 2026)).

Life insurance coverage. The employee became ill after eating raw oysters and died a week later from septic shock. At the time of her death in August 2021, the employee worked for Accenture LLP, and was enrolled in a life insurance plan offered by the company. Her plan included “basic” accidental life insurance coverage equal to her salary and additional “optional” accidental death and dismemberment (AD&D) coverage of three times her salary. The employee designated her husband as her beneficiary.

Accenture prepared a summary plan description (SPD) of its life insurance and AD&D plans. The 2020 and 2021 SPDs identified Accenture as the plan administrator. The claims administrators for those years were MetLife (2020) and Prudential Insurance Company of America (2021). According to the SPDs, benefits would “be paid only if the Plan Administrator and/or Claims Administrator decide in its discretion that the claimant is entitled to them.”

Administrators’ roles. The SPDs also delineated the roles of the Plan and Claims Administrators. As Plan Administrator, Accenture was “responsible for formulating and carrying out all rules and regulations necessary to administer the Plan and ha[d] the sole discretionary authority to make decisions regarding eligibility of employees and participants in each Plan.”

In 2021, Accenture designated Prudential as Claims Administrator and “delegated” to it “the discretionary authority to make decisions regarding the interpretation or application of Plan provisions” and “to determine all questions, including factual determinations, as to the rights and benefits of employees and participants under each Plan.”

Benefits claims. The employee’s husband submitted a claim for both basic accidental and optional accidental life insurance benefits to Prudential. The claim was denied because the employee died of a “medical illness and/or sickness” and not an “Accidental Injury... as the direct result of an Accident.” The husband pursued an administrative appeal through Prudential’s internal process but fared no better.

The husband then sued Prudential and Accenture. Prudential settled, so only the claims against Accenture are pertinent to this appeal. The husband alleged that Accenture wrongly denied his benefits claim under ERISA § 502(a)(1) and breached its fiduciary duties to his wife by failing to furnish her with the SPDs.

In dismissing the husband’s claims, the district court explained that he did not state a claim for wrongful denial of benefits under ERISA § 502(a)(1) because he did not allege facts demonstrating that “Accenture controlled the claims administration of benefits.” It also held that he failed to state a plausible claim for breach of fiduciary duty under ERISA §§ 502(a)(2) or (a)(3).

After receiving the district court’s dismissal order, the husband filed an amended complaint, but the district court again dismissed his claims. The district court denied his motion for leave to file a second amended complaint. He timely appealed.

Appeal. This appeal required the Third Circuit to decide whether an employer that lacks authority over benefit determinations may be sued for denial of benefits under ERISA. The ERISA claims against Accenture fell into two categories: (1) the benefit denial claim; and (2) the SPD claim. The appeals court determined that neither claim was plausible, and that because further amendment would be futile, the district court did not err in denying the husband’s motion for leave to file his second amended complaint.

Proper defendant. The husband argued that Accenture was a proper defendant for his denial of benefits claim because it had the authority to make benefits determinations. But, the appeals court explained, that a plausible suit for “benefits due” must be brought against a party with an obligation to pay. Sometimes that will be the plan, and sometimes that will be the insurance company that adjudicates claims. The latter is the case here: “Prudential must be given written proof of the loss including any requested documentation.” The plan did not confer Accenture any authority over claims administration, and the husband did not provide evidence plausibly suggesting otherwise. So, Accenture was not a proper defendant for his denial of benefits claim, and the district court was right to dismiss this claim.

In holding that the proper defendant in an ERISA § 502(a)(1)(B) claim is one who controls benefits determinations, the Third Circuit aligned itself with five other circuits, including the Seventh, Eighth, Sixth, Eleventh, Fifth Circuits. Two other circuits, the Second and Ninth Circuits, have explained that those who exercise control over benefit determinations are the appropriate defendants in ERISA § 502(a)(1)(B) claims.

Amended complaint. The district court provided the husband with the opportunity to re-plead facts that supported his theory that Accenture was involved in the claim decision, but his second amended complaint highlighted only a single document from that record. This addition to the pleading, however, did not plausibly allege any involvement by Accenture in the AD&D claim decision.

The husband also argued that Accenture retained authority to make benefit determinations based on language in the SPDs that states, “[b]enefits under the Plans will be paid only if the Plan Administrator and/or Claims Administrator decide in its discretion that the claimant is entitled to them.” But to the extent he relied on the 2020 and 2021 SPDs, they are not the terms of the plan. Moreover, the SPD language highlighted by the husband showed only that, depending on the issue at hand, either Accenture or Prudential may have a particular plan responsibility. Accenture had authority for limited issues like eligibility, while Prudential was the Claims Administrator and had authority to process and decide claims.

Because Accenture delegated claims administration duties to Prudential, Prudential was the proper defendant for the husband’s denial of benefits claim. Accordingly, the husband had no ERISA § 502(a)(1)(B) claim against Accenture, and the district court did not err in dismissing the case with prejudice or in denying him leave to amend.

SPD claim. The husband’s SPD claim fared no better. Whether construed as a failure to provide required plan documents claim under ERISA § 104(b)(1) or a breach of fiduciary duty claim under ERISA § 404, the husband’s second amended complaint failed to plausibly state a claim upon which relief could be granted.

ERISA § 104(b)(1) specifies that plans must provide participants and beneficiaries with an SPD within 90 days of enrollment. And ERISA § 102 specifies that SPDs must “be written in a manner calculated to be understood by the average plan participant” and “reasonably apprise such participants and beneficiaries of their rights and obligations under the plan.”

The husband did not plead facts that would support a claim against Accenture under ERISA § 104(b)(1) for failure to provide an SPD. Further, his SPD allegations did not state a claim for a breach of fiduciary duty either. He did not allege that Accenture’s failure to provide his late wife with the relevant SPDs deprived her of any information, or even if it had, how that deprivation was material.

Accordingly, the Third Circuit affirmed the district court’s orders denying leave to file a second amended complaint, denying reconsideration, and dismissing the complaint with prejudice.

The case is No. 25-2084.

Judge: Hardiman, T.

Attorneys: Roman J. Koropey (Timoney Knox) for Mark L. Justman. Nathan T. Boone (Littler Mendelson) for Accenture LLP.

Companies: Accenture LLP; Prudential Insurance Company of America

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