Helton v. AT&T
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This case: Helton v. AT&T
Helton v. AT & T INC.
Helton v. AT & T INC. Court of Appeal.
No. 11-2153 (4th Cir. Mar. 6, 2013)
Helton is an employee participant wanted to be awarded her lost benefits by AT & T Inc. She learned that she was entitled to full pension benefits almost eight after leaving the company. She left the company without applying for retirement benefits (Helton v. AT & T INC, 2013). She understood she was not eligible for the benefits. AT & T Inc. had not informed Helton there was an amendment made by the company.
Did the district court err in awarding Helton her lost benefits and considering evidence outside the administrative record when it ought to have transferred the case to AT &T for review? Also, considering that the court was restricted from relying on evidence outside the administrative record.
The district court suitably deliberated on limited evidence outside of the administrative record (Helton v. AT & T INC, 2013). The evidence was known to AT & T when it reduced Helton’s benefits determination. Also, the court did not err in granting Helton her lost benefits.
Rules used by the court.
The doubts regarding limitation to the administrative record were resolved by Metropolitan Life Ins. Co. v. Glenn, 554 U.S. 105 (2008). It requires deliberation of the possible conflict of interest as part of the abuse-of-discretion assessment (Helton v. AT & T INC, 2013). It should include deliberation of non-record evidence. The denial of benefits did not match the express terms of the retirement plan. The plan administrator did not compile enough record and the plan had a structural conflict.
The district court relied enough evidence when settling on whether the benefits Committee depended on enough materials when it denied Helton’s appeal. AT &T was aware of the evidence when the Benefits Committee made its decision (Helton v. AT & T INC, 2013). Section 22.7.1 of the Pension Plan during the time Helton pursued to recover her lost benefits, permitted the Pension Plan administrator to confer “recuperative” benefits.
AT & T Inc was required to grant Helton the lost benefits. In its decision, the court did not focus on whether the evidence presented was part of the administrative record (Helton v. AT & T INC, 2013). Rather, it focused on whether the plan administrator was aware of the evidence provided when it gave its decision.
Helton v. AT & T INC. Court of Appeal. No. 11-2153 (4th Cir. Mar. 6, 2013)