In Williams v. FedEx Corporate Servs., 849 F.3d 889 (10th Cir. 2017), plaintiff sued FedEx for violating the Americans with Disabilities Act (ADA) by requiring him to enroll in the company’s substance abuse and drug testing program. He also sued Aetna, FedEx’s STD insurer, for breach of fiduciary duty for reporting to FedEx that plaintiff had filed a disability claim for substance abuse. The district court granted summary judgment for defendants on both claims.
The Court reversed the ADA decision, and remanded to the district court for further evaluation of one of FedEx’s defenses.
Turning to the ERISA claim, the Court noted that Aetna, as fiduciary, must discharge its duties solely in the interest of the participants and the beneficiaries, and “must also provide complete and accurate information.” The Court held that Aetna did not act arbitrarily or capriciously.
First, Aetna did not breach its fiduciary duty by determining that plaintiff was disabled due to chemical dependency, because this “claim does not appear to be a breach of fiduciary duty claim, but instead an attempt to challenge Aetna’s benefits determination.
Next, the Court observed that FedEx’s plan specifically obligated Aetna to notify FedEx if an employee sought benefits for substance abuse. The Court held that Aetna’s compliance with the terms of the plan cannot constitute a breach of fiduciary duty.
Finally, the Court held that Aetna did not breach its fiduciary duty by declining to change its report to FedEx after Aetna received additional information about plaintiff’s claim, because the additional information did not render Aetna’s report inaccurate.