Pietrofitta

This is a cautionary tale for ERISA administrators. We are met with three claimants to an ERISA-governed life insurance policy held by the decedent, Scott Parker: Anita Pietrofitta, his widow; Eileen Marrero, his ex-wife; and the Estate of Scott Parker, which represents Zachary Dry, a son born to a third woman five months after Parker died. Metropolitan Life Insurance Company (“MetLife”) declared the policy proceeds owing but could not identify the proper beneficiary and filed this action in interpleader in the District of Arizona. We narrow the field from three to two and remand to the district court for further findings of fact.

I. BACKGROUND AND PROCEEDINGS

The Employee Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1001 et seq. governs the administration of employer-provided benefit pension plans. Congress passed the Act to protect the interests of the participants in these plans and their designated beneficiaries and to provide employers with uniform guidelines and rules regarding the administration of benefit plans. See 29 U.S.C. §§ 1001 (a)-(c), 1001b(a)-(c). The two most basic components of any ERISA plan are the plan administrator and the plan documents. The plan…