A single ignored paperwork request now has the plan facing possible penalties
A federal appeals court has reminded benefits administrators that plan paperwork carries real obligations - and that ignoring a document request can carry a price.
On August 10, 2026, the US Court of Appeals for the Fourth Circuit largely ruled for Altria Client Services and its retirement plan in a long-running ERISA dispute, but reversed on one point that should get the attention of anyone who runs a benefits function.
The case began with a former Altria employee who kept his 401(k) account after his job was eliminated in 2010. Ahead of the 2020 election, he expected a market bump and wanted to liquidate holdings, move the cash to Goldman Sachs and capture certain tax benefits. He and his advisers called Fidelity Workplace Services, the plan's record keeper, to speed things up. When the transfers did not clear as fast as he hoped, he filed a formal claim. The plan administrator denied it, and an internal management committee upheld that denial.
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.
