In re Faris, 2 Wn. App. 2d 1039 (Div. 1 Feb. 20, 2018), rev. denied, 190 Wn.2d 1030 (2018) (unpublished)
Feb 20, 2018OUTCOME: Affirmed on appeal to the Washington State Division I Court of Appeals
Seattle, WA
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OUTCOME: Affirmed on appeal to the Washington State Division I Court of Appeals
OUTCOME: Reversal of Summary Judgment on appeal to the Ninth Circuit
HOLDINGS: [1]-Beneficiary designation forms were not "plan documents" for purposes of 29 U.S.C.S. § 1104(a)(1)(D) and therefore did not govern a plan administrator's award of benefits under a decedent' ... s retirement plans, nor did the plan documents incorporate the beneficiary designation forms. The district court therefore erred in finding that the decedent was required to abide by the language contained in the forms to change his beneficiary designation from his ex-wife to his son; [2]-The plan administrator did not exercise its authority to require the beneficiary forms' use, as the administrator declined to award benefits to either the ex-wife or the son and instead filed the instant interpleader action; [3]-The ex-wife was improperly awarded summary judgment, as the governing plan documents permitted unmarried participants to change their beneficiary designations by telephone.