Plan Language and Process: Two Recent Court Decisions Employers and Plan Administrators Need to Know About
If you sponsor or administer an employee benefit plan, two recent federal court decisions should be on your radar. Taken together, Phillips v. Boilermaker-Blacksmith National Pension Trust (10th Cir. Sept. 29, 2026) and Macpeak v. Unum Life Insurance Co. of America (E.D. Pa. Sept. 28, 2026) deliver a clear message: benefit plan administrators must follow the plan's own language when making benefits decisions—and they must follow proper procedures when communicating those decisions to participants. Falling short on either front can expose plan sponsors, insurers, and administrators to significant liability.
Here is what happened in each case and what it means for your organization.
Lesson One: You Cannot Override Clear Plan Language—Even With Broad Discretionary Authority
Both decisions involved plan administrators that strayed from the plain text of their own plan documents when denying or terminating benefits.
The Pension Case: Phillips v. Boilermaker
In Phillips, a group of boilermakers applied for early retirement benefits under a multiemployer pension plan. The plan stated that a participant could retire early by "withdraw[ing] completely and refrain[ing] from employment" in job classifications traditionally covered by a collective bargaining agreement or from supervising workers in those jobs. Many of the boilermakers stopped doing union-classified work but took other jobs, sometimes with employers that happened to contribute to the pension plan.
The plan's board of trustees denied their early retirement claims, interpreting "withdraw completely" to mean quitting all work for any employer contributing to the plan. The Tenth Circuit Court of Appeals disagreed, finding the plan language unambiguous: it only restricted participants from specific types of covered work and supervisory roles, not from all employment with a contributing employer. As the court put it, if a boilermaker quit and joined a sporting goods store, that new job would not prevent early retirement benefits unless sporting goods stores are employers traditionally covered by a collective bargaining agreement.
Importantly, the plan gave its trustees broad discretion to interpret and apply plan terms. But the court made clear that discretionary authority does not allow an administrator to adopt an interpretation that conflicts with unambiguous plan language. When the plan says one thing and the administrator does another, the administrator loses, regardless of the standard of review.
The Disability Case: Macpeak v. Unum
In Macpeak, an attorney at a major law firm who specialized in securities law had received long-term disability benefits for years. In 2023, her insurer, Unum, terminated those benefits after determining she could perform the duties of an "Attorney," without reference to the specific duties performed by the employee or her job description. However, the plan did not define "regular occupation" for attorneys as the generic practice of law. Instead, it specifically defined it as the attorney's "specialty in the practice of law." Despite this clear language, Unum's vocational reviewer assessed the plaintiff against the duties of a general attorney, including trial work, patent and copyright applications, labor disputes, and college teaching, none of which had anything to do with her actual securities law practice. Unum's medical consultants likewise evaluated only generic physical and cognitive demands rather than what the court called the “material and substantial” duties specific to a securities lawyer.
The court found this was an abuse of discretion. Even under the deferential arbitrary-and-capricious standard, the administrator's decision could not stand because it flatly contradicted the plan's own definition. The court ordered retroactive reinstatement of benefits back to the termination date, plus prejudgment interest.
The Takeaway for Your Organization
These cases reinforce a principle that applies across every type of benefit plan: the plan document controls. Discretionary authority gives administrators room to make reasonable judgment calls—it does not give them permission to rewrite or ignore the plan's terms. Whether you are administering a pension plan, a disability plan, a health plan, or any other ERISA-covered arrangement, your decisions must be grounded in the plan's actual language. If the plan says "specialty," don't evaluate a generalist. If the plan says "covered work," don't expand that to mean all work.
Lesson Two: Defective Denial Notices Can Destroy Your Limitations Defense
Even when an administrator reaches the right result on the merits, procedural failures in communicating that result to participants can be equally costly. Phillips illustrates this point dramatically.
Under the boilermakers' plan, a participant who wanted to challenge a denied claim in court had to file suit within two years of an adverse decision. Federal regulations require that every denial letter tell the participant how long they have to bring a civil action. But the plan administrator denied the initial claims of 69 boilermakers without including that information. The Tenth Circuit held that the administrator could not enforce the two-year deadline against any of those 69 participants. The administrator tried to fix the problem by including the deadline in the letters denying administrative appeals. But those appeal letters had their own deficiencies: they failed to identify the specific plan provision on which the denial was based, as required by ERISA. Because the appeal denials were themselves defective, the court found they could not cure the earlier omissions.
The practical consequence was enormous: dozens of claims that the administrator could have defeated on timeliness grounds were allowed to proceed. And the court noted that every circuit to address the issue has reached the same conclusion about the disclosure requirement.
The Takeaway for Your Organization
Every benefit denial letter—whether at the initial determination stage or on appeal—must include all of the elements required by ERISA's claims procedure regulations (29 C.F.R. § 2560.503-1). At a minimum, that means:
- The specific reasons for the denial
- References to the specific plan provisions on which the denial is based
- A description of any additional material or information needed and why it is necessary
- A description of the plan's review procedures, including the right to bring a civil action and the applicable time limits for doing so
If your denial templates do not include each of these elements, you may be unable to enforce your plan's contractual limitations period—even when the deadline has long passed. This is an issue that HR professionals, third-party administrators, and their legal counsel should audit immediately.
Putting It All Together
These cases share a common theme: benefit plan administration demands both substance and process. Getting the answer right on the merits requires faithful application of the plan's own language. Communicating that answer properly requires strict compliance with federal procedural requirements. Fail on either front, and the consequences can range from reinstated benefits and back payments to the loss of critical litigation defenses.
For employers, TPAs, and their advisors, the action items are straightforward:
- Review your plan documents carefully. Make sure the people making benefits determinations understand the specific definitions, eligibility criteria, and standards the plan actually uses—not what they assume the plan says.
- Audit your denial letter templates. Confirm that every template—for both initial denials and appeal denials—includes every element required by regulation. Do not assume a deficiency at one stage can be fixed at the next.
- Train your teams. Claims reviewers, vocational consultants, and medical reviewers should all be working from the plan's actual terms, not generic industry descriptions or national-economy databases that may not match the plan's definitions.
- Document your reasoning. When a close call arises, document how the plan language supports the decision. Courts review the administrative record, and a well-documented file is the best defense against a finding that the decision was arbitrary or capricious.
Disciplined adherence to your plan language and claims procedures protects your organization, your plan participants, and your bottom line.
This post is for informational purposes only and does not constitute legal advice. If you have questions about your plan's compliance with ERISA requirements, please contact us.