Kantor & Kantor represented a beneficiary whose ERISA-governed life insurance claim was denied after the insured’s death, leaving the family without benefits intended to replace income and provide financial stability following the loss. While the insurance appeal was pending, the beneficiary entered into an employment separation agreement after being advised that the insurer was a separate entity and that the agreement would not affect the pending benefits claim.
After the appeal proceeded, Sun Life asserted for the first time that the employment release barred the ERISA claim against the insurer. Sun Life relied on broad release language directed at the employer and attempted to extend it to the insurer, despite the absence of any express waiver of life insurance benefits and despite representations made to the claimant at the time of separation.
The Second Circuit rejected Sun Life’s attempt to use an employment agreement to avoid paying life insurance benefits. The court held that waivers of ERISA rights must be knowing, explicit, and informed, and it foreclosed insurers from piggybacking on employer releases to extinguish independent benefit obligations.
