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.

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