Conkright v. Frommert

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Conkright v. Frommert
Seal of the United States Supreme Court.svg
Decided April 21, 2010
Full case nameConkright v. Frommert
Citations559 U.S. 506 ( more )
Holding
The administrator of an ERISA plan is entitled to deference in matters of interpretation, even when the administrator had previously adopted a different interpretation that a court found erroneous.
Court membership
Chief Justice
John Roberts
Associate Justices
John P. Stevens  · Antonin Scalia
Anthony Kennedy  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Samuel Alito  · Sonia Sotomayor
Case opinions
MajorityRoberts
DissentBreyer, joined by Stevens, Ginsburg
Sotomayor took no part in the consideration or decision of the case.

Conkright v. Frommert, 559 U.S. 506(2010), was a United States Supreme Court case in which the court held that the administrator of an ERISA plan is entitled to deference in matters of interpretation, even when the administrator had previously adopted a different interpretation that a court found erroneous. [1] [2]

Contents

Background

The petitioners in this case were Xerox Corporation's pension plan (Plan) and the Plan's current and former administrators (Plan Administrator). The respondents were employees who left Xerox in the 1980s, received lump-sum distributions of retirement benefits earned up to that point, and were later rehired. To account for the past distributions when calculating respondents' current benefits, the Plan Administrator initially interpreted the Plan to call for an approach that has come to be known as the "phantom account" method. Respondents challenged that method in an action under the Employee Retirement Income Security Act of 1974 (ERISA). [1]

The federal District Court granted summary judgment for the Plan, but the Second Circuit Court of Appeals vacated and remanded. It held that the Plan Administrator's interpretation was unreasonable and that respondents had not received adequate notice that the phantom account method would be used to calculate their benefits. On remand, the Plan Administrator proposed a new interpretation of the Plan that accounted for the time value of the money respondents had previously received. The District Court declined to apply a deferential standard to this interpretation, and adopted instead an approach proposed by respondents that did not account for the time value of money. Affirming in relevant part, the Second Circuit held that the District Court was correct not to apply a deferential standard on remand, and that the District Court's decision on the merits was not an abuse of discretion. [1]

Opinion of the court

The Supreme Court issued an opinion on April 21, 2010. [1]

Subsequent developments

References

  1. 1 2 3 4 Conkright v. Frommert, 559 U.S. 506 (2010).
  2. Christensen, Anna (April 24, 2010). "Court rules on deference for retirement plan administrators". SCOTUSblog. Retrieved September 2, 2025.

This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain .