Plaintiff Helton began working for AT”&T in 1980. In April 1997, she book paid vacation time, and after that was exhausted, an unpaid leave of absence fro AT&T to open a home-cooking restaurant. She formally resigned from the company on May 31, 1997. At the time she left, she correctly believed that she was not eligible to receive benefits under the plan until she turned 65. In August 1997, AT&T amended the Plan through a “Special Update” which, among other things, allowed certain participants, including Helton, to elect benefits at age 55, without facing any benefit reduction. AT&T sent notice to active management employees on August 28, 2997, and included a notification in the Summary Plan Description (SPD) on January 1, 1998. Helton did not receive either of these. Helton learned in 2009 that she had been entitled to begin collecting her full pension benefits nearly eight years earlier. She contacted her pension plan seeking to recoup her lost benefits, but the pension plan denied her claim. Helton sued under ERISA. At trial, the district court admitted limited evidence outside of the administrative record but known to AT&T at the time it made its benefits determination re Helton, and found that AT&T unreasonably denied Helton’s claim, failed to adequately notify her of a material change to its pension plan, and that AT&T breached its statutory and fiduciary duties to her.

1. What were the legal issues in this case? What did the appeals court decide?

2. Why is the question of whether courts should consider “extrinsic evidence” significant in this type of case? What does the appeals court conclude about the consideration of such evidence?

3. What factors does the court consider in deciding whether a plan administrator has abused his or her discretion in denying a benefit claim? How were these factors applied to the facts of this case?

4. How were ERISA’s reporting and disclosure requirements violated in this case?