Altria owes a former worker a copy of its benefits contract

He then sued under ERISA – the federal law governing workplace retirement and benefit plans – arguing he was wrongly denied benefits and that Fidelity had breached a fiduciary duty by misstating how long the transfers would take. 

The court rejected both arguments. On the benefits denial, it applied a highly deferential standard and found the administrator’s decision reasonable and supported by the record. On the fiduciary claim, it held that Fidelity was a ministerial record keeper, not a fiduciary, and that even if it were, it broke no duty because it gave accurate time estimates that the transactions met. 

The reversal came on a quieter issue with wide reach. The former employee had asked for a copy of the Administrative Services Agreement between the plan and Fidelity. The administrator refused, saying the contract did not govern participants. The Fourth Circuit disagreed, holding that the agreement was a document “under which the plan operated” and that he was entitled to a copy. It sent the case back to decide whether statutory penalties apply. 

For HR and benefits teams, that is the practical signal. Service and record-keeping contracts can fall within the documents a plan must produce on a participant’s written request – and a refusal can expose the administrator to penalties. The plan also recovered attorney’s fees of $76,131, with the record keeper awarded $46,820. 

The decision is final at the appeals stage, though the penalty question now returns to the district court, which must decide whether any penalties are appropriate.