Andochick v. Byrd’s Empirical Analysis

Citation profile

1 federal appellate · 2 district · 5 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Allowing post-distribution suits to enforce state-law waivers does nothing to interfere with any of these objectives. For in situations like that at issue here, Kennedy merely dictates that the plan administrator distribute plan benefits to the named beneficiary. This ensures simple administration regardless of whether post-distribution suits are permitted, because the plan administrator would have no role in any post-distribution proceedings. For the same reason, post-distribution suits do not expose the plan administrator to double liability— only the named beneficiary has any claim against the plan administrator.”

   1 later decision quote this exact passage · from the majority
   e.g. Wendy Jeanelle Hennig v. Matthew Michael Didyk

2. “the Supreme Court held that an ERISA plan administrator must distribute benefits to the beneficiary named in the plan, regardless of any state-law waiver purporting to divest that beneficiary of his right to the benefits.”

   1 later decision quote this exact passage · from the majority
   e.g. 389 F. Supp. 3d 979 - Evans v. Diamond

3. “Kennedy explicitly left open the question of whether, once the benefits are distributed by the administrator, the decedent's estate can enforce a waiver against the plan beneficiary.”

   1 later decision quote this exact passage · from the majority
   e.g. 389 F. Supp. 3d 979 - Evans v. Diamond