McGuffie vs Anderson Re-Order Granting

This is an ERISA case removed from the Circuit Court of Warren County to the United States District Court for the Southern District of Mississippi.  The plaintiff’s husband, Robert McGuffie, was a retired employee of Anderson-Tully Lumber Company.  Before he retired, Robert McGuffie was married to Mary Jo and identified Mary Jo as his spouse on a retirement election form in which he elected that his spouse receive benefits in the form of a qualified joint and survivor annuity (“QJSA”).  Mary Jo passed away subsequent to Robert’s retirement and Robert thereafter remarried the plaintiff, Knoxie.  However, by the time Robert married Knoxie he had already begun receiving pension benefits through the Plan.  After Robert’s death, the plaintiff made a claim to Anderson-Tully for benefits through the QJSA which Robert had elected at the time of his retirement and had identified his then spouse, Mary Jo, as its recipient.  Anderson-Tully denied the plaintiff’s claim because Mary Jo, not Knoxie, was Robert’s spouse at the time Robert’s retirement benefits commenced.  The plaintiff thereafter sued Anderson-Tully under various theories of recovery.  Given that the plaintiff’s suit was completely preempted by ERISA, Anderson-Tully removed to the United States District Court for the Southern District of Mississippi.  Anderson-Tully filed a motion for summary judgment, arguing that Knoxie was not entitled to benefits under the QJSA because she was not married to Robert at the time his benefits commenced.  The District Court held that the Anderson-Tully did not abuse its discretion in making the benefits determination, finding that a husband’s ERISA plan pension benefits irremovably vest in favor of the wife on the date of the retirement and such is not altered by a subsequent marriage.  The Court further found that this is the most practical and actuarially sound conclusion because it is the life expectancy of the participant and his or her spouse at the commencement of retirement benefits which determines the payout period for the annuity and there is no mechanism in the Plan to permit transfer and recalculation of the survivor annuity based on a subsequent spouse’s life expectancy.  Based on those findings, the Court dismissed the plaintiff’s suit and awarded judgment in favor of Anderson-Tully.