ERISA § 502(a)(1)(B): Only the Entity that Controls Benefit Determinations Is a Proper Defendant (Third Circuit)

1. Introduction

Case: Mark Justman v. Accenture LLP, No. 25-2084 (3d Cir. June 17, 2026) (precedential).
Parties: Mark L. Justman (individually and as executor of Karen A. Justman’s estate) sued Accenture LLP (employer/Plan Administrator in the SPDs) and Prudential Insurance Company of America (claims administrator/insurer for 2021). Prudential settled; the appeal concerns only Accenture.
Context: After Karen Justman’s death in 2021, her husband sought accidental death and AD&D benefits under an Accenture-sponsored ERISA plan. Prudential denied the claim, concluding the death resulted from illness/sickness rather than “Accidental Injury” caused by an “Accident.”

Core issues on appeal:

  • Proper defendant: Whether Accenture can be sued under ERISA § 502(a)(1)(B) for wrongful denial of benefits when the plan documents place claims administration and benefit determinations with Prudential.
  • SPD-related liability: Whether allegations that Accenture failed to provide the 2020/2021 Summary Plan Descriptions (SPDs) plausibly state a claim under ERISA § 104(b)(1) and/or a breach of fiduciary duty theory (invoked through ERISA § 502(a)(3)).
  • Pleading posture: Whether the District Court correctly denied leave to file a Second Amended Complaint as futile and dismissed with prejudice.

2. Summary of the Opinion

The Third Circuit affirmed the dismissal with prejudice and the denial of leave to amend. It held:

  1. ERISA § 502(a)(1)(B): A wrongful denial of benefits claim must be brought against a party that controls benefit determinations (i.e., has authority over claims administration/decision-making). Because Prudential—not Accenture—decided the claim and the plan did not confer claims-decision authority on Accenture, Accenture was not a proper defendant.
  2. SPDs: The proposed amended pleading did not plausibly allege a statutory violation of ERISA’s SPD disclosure deadlines under § 104(b)(1), nor the elements of a fiduciary breach based on nondisclosure.
  3. Futility: Further amendment would be futile; denial of leave and dismissal with prejudice were proper.

3. Analysis

3.1. New/Clarified Rule in the Third Circuit

This precedential decision adopts (and harmonizes with existing nonprecedential Third Circuit guidance) a clear defendant-identity rule for ERISA denial-of-benefits actions:

In an ERISA § 502(a)(1)(B) claim, the proper defendant is the entity that controls benefit determinations (i.e., exercises authority over claims administration/benefits decisions), because a “benefits due” action must be brought against a party with an obligation to pay or decide entitlement under the plan’s terms.

The court also reinforces two related propositions:

  • SPDs are not plan terms for § 502(a)(1)(B) purposes (CIGNA Corp. v. Amara).
  • SPD nondisclosure claims must plead timing and statutory triggers (enrollment date, amendment/material modification, and whether a statutory deadline passed).

3.2. Precedents Cited (and How They Shaped the Decision)

A. Proper defendant for § 502(a)(1)(B)

The court emphasized ERISA’s silence on “who may be sued,” then adopted the “control over benefit determinations” approach aligned with other circuits:

  • Larson v. United Healthcare Ins. Co., 723 F.3d 905, 913 (7th Cir. 2013): Cited for the proposition that § 502(a)(1)(B) identifies who may sue but not who may be sued, supporting the need for a functional rule tethered to claims control/obligation.
  • Brown v. J.B. Hunt Transp. Servs., Inc., 586 F.3d 1079, 1081, 1088 (8th Cir. 2009): Reinforces that the defendant must be the party responsible for benefit determinations/administration.
  • Moore v. Lafayette Life Ins. Co., 458 F.3d 416, 438 (6th Cir. 2006): Supports suing the insurer/claims decisionmaker where it controls eligibility for payment.
  • Heffner v. Blue Cross & Blue Shield of Ala., Inc., 443 F.3d 1330, 1333-34 (11th Cir. 2006): Cited for the same control-based proper-defendant approach.
  • Musmeci v. Schwegmann Giant Super Mkts., Inc., 332 F.3d 339, 349 (5th Cir. 2003): Another endorsement of the functional “control” standard.
  • New York State Psychiatric Ass'n, Inc. v. UnitedHealth Grp., 798 F.3d 125, 132 (2d Cir. 2015): While framed somewhat differently, it supports the conclusion that entities exercising control over benefit determinations are appropriate defendants.
  • Cyr v. Reliance Standard Life Ins. Co., 642 F.3d 1202, 1205-07 (9th Cir. 2011) (en banc): Used to bolster the broad acceptability of suing the claims-controlling insurer/administrator.
  • Evans v. Emp. Benefit Plan, Camp Dresser & McKee, Inc., 311 F. App'x 556, 558 (3d Cir. 2009): A Third Circuit panel previously explained that “control over the administration of benefits” is the defining feature of the proper defendant; the present precedential opinion “tracks” that approach and elevates it to binding circuit law.

B. SPDs are not enforceable “plan terms” in § 502(a)(1)(B) litigation

  • CIGNA Corp. v. Amara, 563 U.S. 421, 438 (2011): Central to rejecting the plaintiff’s reliance on SPD language suggesting the Plan Administrator “and/or” Claims Administrator decides entitlement. The court used Amara to hold that SPD wording cannot create plan terms that expand Accenture’s claims-decision authority for § 502(a)(1)(B) purposes.

C. Pleading standards, amendment, and post-judgment motions

  • Mullin v. Balicki, 875 F.3d 140, 150 (3d Cir. 2017): Supplies the de novo standard for denial of leave to amend when grounded in failure to state a claim; supports affirmance based on futility.
  • Cook v. GameStop, Inc., 148 F.4th 153, 157 (3d Cir. 2025): Cited for the abuse-of-discretion review of dismissal with prejudice.
  • Lazaridis v. Wehmer, 591 F.3d 666, 669 (3d Cir. 2010): Sets the reconsideration standard (intervening change in law, new evidence, clear error/manifest injustice).
  • Herrera v. Agents of Pennsylvania Bd. of Prob. & Parole, 132 F.4th 248, 254 n.5 (3d Cir. 2025): Reinforces the reconsideration framework.
  • Grayson v. Mayview State Hosp., 293 F.3d 103, 108 (3d Cir. 2002): Supports dismissal with prejudice where amendment would be futile.

D. Fiduciary-duty nondisclosure framework

  • In re Unisys Corp. Retiree Med. Benefits ERISA Litig., 579 F.3d 220, 228-29 (3d Cir. 2009): Provides the elements for fiduciary breach premised on misrepresentation or inadequate disclosure: fiduciary capacity, misrepresentation/insufficient disclosure, materiality, and detrimental reliance (as articulated there). The court used this structure to find the complaint missing materiality and reliance (and, even under an “actual harm” theory, missing harm tied to nondisclosure).

3.3. Legal Reasoning

A. Why Accenture was not a proper § 502(a)(1)(B) defendant

The court’s reasoning is document-centered and functional:

  • Plan mechanics: The plan required written proof to Prudential and provided that benefits would be paid “when Prudential receives written proof of the loss.” This anchored the obligation-to-pay and entitlement decision with Prudential.
  • Allocation of authority: Even though the SPDs listed Accenture as Plan Administrator with discretion over eligibility, they described a delegation to Prudential for “claim processing, claim investigation, claim control, and the daily administration of the plan,” and the SPDs repeatedly described accident determinations as made by the “Claims Administrator.”
  • No plausible factual hook: After being given opportunities (and record access), the plaintiff’s added fact—a Prudential letter to Accenture offering a phone number if Accenture had questions—suggested Prudential was the decisionmaker and Accenture was not involved in the adjudication.
  • SPD-as-plan-terms rejected: Any ambiguity the plaintiff attempted to derive from the SPDs could not create enforceable plan terms under § 502(a)(1)(B) due to CIGNA Corp. v. Amara.

B. Why the SPD claims failed (statutory and fiduciary theories)

The opinion treats “SPD claims” as potentially falling under either (i) ERISA’s disclosure timing rules or (ii) fiduciary breach for nondisclosure, and finds both inadequately pleaded:

(i) ERISA § 104(b)(1) timing theory
  • The complaint failed to plead basic triggering facts: when enrollment occurred (for the 90-day rule), whether/when a five-year update deadline applied, and whether any “modification or change” occurred that would require an updated SPD within 210 days after plan year-end (or 60 days for certain health-plan reductions—likely irrelevant here).
  • Even assuming the insurer switch from MetLife (2020) to Prudential (2021) was a qualifying change and the plan year was the calendar year, an SPD reflecting that change would not have been due until July 2022—after Ms. Justman’s death in August 2021—defeating plausibility of a missed deadline.
  • The court noted the District Court misstated “270 days” and miscalculated dates, but deemed the errors non-prejudicial because the pleading still failed under the correct “210 days” rule.
(ii) Fiduciary breach / § 502(a)(3) equitable relief theory
  • The plaintiff did not plausibly allege materiality: he did not show what meaningful information was withheld that mattered to coverage, claims, or choices.
  • The plaintiff did not plausibly allege reliance (as framed by In re Unisys): he did not allege he or Prudential relied on an SPD to deny or process the AD&D claim.
  • The plaintiff’s asserted “harm” (nonpayment of benefits) was not connected to SPD nondisclosure; the dispute turned on medical/causation classification (accident vs illness), and the complaint acknowledged he filed the claim even without SPDs.
  • Even accepting the plaintiff’s argument that some equitable theories require only “actual harm” rather than detrimental reliance, the complaint still did not plead harm caused by the alleged nondisclosure.

3.4. Impact

A. Litigation targeting and early dismissal

The most immediate impact is procedural and strategic: in the Third Circuit, plaintiffs bringing § 502(a)(1)(B) claims must aim the complaint at the entity that actually decides claims or controls benefit determinations (often the insurer or third-party administrator), not necessarily the employer or nominal Plan Administrator. Defendants can use this precedent to:

  • seek Rule 12(b)(6) dismissal when the employer lacks claims-decision authority;
  • focus discovery disputes by anchoring “control” in plan documents and the administrative record;
  • reduce “shotgun” ERISA pleading that names every entity in the benefits ecosystem.

B. Document hierarchy: plan vs. SPD

The decision reinforces Amara in a practical pleading context: plaintiffs cannot transform SPD phrasing into plan terms to create or expand claims-decision authority for § 502(a)(1)(B). Future plaintiffs may need to:

  • plead and attach (or quote) controlling plan instruments (group policy, plan document), not just SPDs;
  • use § 502(a)(3) theories where SPD misstatements cause harm, rather than trying to enforce SPD language as plan terms under § 502(a)(1)(B).

C. SPD nondisclosure claims: required specificity

The opinion underscores that SPD timing claims are not “notice pleading by label.” A viable § 104(b)(1) claim generally requires plausible allegations about:

  • enrollment date (for the 90-day delivery rule),
  • plan amendment or other trigger,
  • the plan year and the applicable statutory deadline (e.g., 210 days after year-end), and
  • why the deadline elapsed before the participant’s relevant injury (here, death).

4. Complex Concepts Simplified

  • ERISA § 502(a)(1)(B): The main ERISA lawsuit tool for recovering benefits “due under the terms of the plan.” It is typically aimed at whoever decides the claim and must pay it.
  • Plan Administrator vs. Claims Administrator:
    • Plan Administrator (often the employer) handles plan governance tasks (e.g., eligibility, plan operations, required notices).
    • Claims Administrator (often an insurer/TPA) processes claims and decides whether benefits are payable.
  • SPD (Summary Plan Description): A participant-facing summary meant to explain the plan. It is important for disclosure duties, but (under Amara) it usually is not itself the enforceable “plan terms” for a § 502(a)(1)(B) benefits lawsuit.
  • Rule 12(b)(6) and “futility”: A case can be dismissed if the complaint does not plausibly state a legal claim. Courts deny further amendments when, even with new allegations, the claim still fails as a matter of law.
  • ERISA § 502(a)(3) “equitable relief”: A separate route for remedies like injunction-like relief, reformation, or surcharge when a fiduciary violation causes harm—often used when § 502(a)(1)(B) is unavailable or inadequate.

5. Conclusion

Justman v. Accenture LLP establishes a clear, precedential Third Circuit rule: a defendant in an ERISA § 502(a)(1)(B) wrongful denial of benefits case must be an entity that controls benefit determinations. Employers and plan administrators cannot be kept in a benefits-denial case absent plausible allegations (grounded in the plan’s operative documents and record) that they actually exercised claims-decision authority.

The decision also tightens pleading expectations for SPD-based claims by requiring factual allegations that connect nondisclosure to statutory timing obligations or to a fiduciary-breach theory through materiality and harm (and, as framed in Third Circuit precedent, reliance). In combination, the opinion channels ERISA litigation toward the correct defendant, the correct documents (plan terms rather than SPD paraphrases), and fact-specific pleading of disclosure violations.