On December 14, 2009, the Middle District of Florida found that a plan administrator’s “apparent lack of understanding and concern with its obligations under ERISA as plan administrator” along with its failure “to act in the best interest of the participant” did not warrant an award of disability benefits. Larsen v. Airtran Airways. Specifically, Airtran’s failure to provide a Summary Plan Description to the claimant, while “negligent”, did not rise to the level of breach (also finding that a constructive trust over past-due benefits is not an available remedy for fiduciary breach under 502(a)(3)). Also, misleading information given to the claimant orally allegedly leading him to refrain from securing his own disability insurance coverage did not warrant relief under the common law claim of equitable estoppel, even with ambiguous plan terms, since intentional deception on the part of the Defendant was not present.
