Second Circuit Holds Plan Fiduciary Breached Duty of Care by Failing to Provide Adequate Notice of Lump-Sum Election During Plan Termination

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Second Circuit Holds Plan Fiduciary Breached Duty of Care by Failing to Provide Adequate Notice of Lump-Sum Election During Plan Termination
Roberts Disability Law

Mar. 4, 2026

"[T]he Second Circuit affirmed a district court judgment finding that a plan fiduciary breached her ERISA duty of care by failing to provide adequate notice regarding a participant's option to elect a lump-sum distribution during plan termination. The court upheld an award of approximately $1.78 million representing the difference between the lump-sum benefit the participant would likely have elected and the much smaller amount ultimately paid to her estate." [Hammell v. Pilot Products, Inc. Defined Benefit Pension Plan, No. 24-3283 (2d Cir. Mar. 3, 2026)] MORE >>

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