Plan label immaterial to determination whether a plan is governed by ERISA

A federal court ruled that “mere labeling by a plan sponsor or administrator is not determinative on whether a plan is governed by ERISA.” Even though DaimlerChrysler utilized ERISA-language in its Summary Plan Description and denial notices, leading one to believe that the plan might be governed by ERISA, what controlled was how the DaimlerChrysler treated the plan in government filings.

In this case, the DaimlerChrysler had not treated the plan as governed by ERISA, and paid the costs of the plan out its general assets, meaning the plan qualified as an ERISA-exempt payroll practice. A Production Supervisor sought disability benefits for anxiety through DaimlerChrysler’s self-insured plan, but was denied. Although the language in the plan led the Production Supervisor to believe the plan was governed by ERISA, the court held in favor of the employee.

About the author: Gregory Michael Dell is an attorney and managing partner of the disability income division of Attorneys Dell & Schaefer. Mr. Dell and his team of disability lawyers have assisted thousands of long-term disability claimants with their claims against every major disability insurance company. Attorney Gregory Dell is a nationally recognized disability insurance attorney and the author of a long-term disability insurance law book published by Thomson Reuters, which is a legal reference for attorneys and judges. For a free consultation, please call 800-828-7583 or use our contact page.

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