Sixth Circuit Reminds Plaintiffs ERISA Estoppel Claims Face Heightened Standard When Challenging Unambiguous Plan Language

In Higgins v. Lincoln Electric Company, No. 23-5862, 2025 U.S. App. LEXIS 1199 (6th Cir. Jan. 16, 2025), the Sixth Circuit reinforced that unambiguous ERISA plan language will be enforced as written and any plaintiff seeking to prevail on an ERISA-estoppel claim must meet a heightened standard.

Plaintiff Jerry Higgins was confronted with an unfortunate situation—his employer, The Lincoln Electric Company, Inc. provided him with a Benefit Election Form that suggested his annual long-term disability (“LTD”) benefit would be $92,260, but the plan documents unambiguously capped those benefits at $60,000. Although Higgins would have sought supplemental disability insurance if he had known the cap would apply, the Western District of Kentucky concluded that Higgins failed to satisfy the heightened standard for ERISA-estoppel claims and dismissed the case.

On appeal, the Sixth Circuit rejected Higgins’ argument that a less demanding standard should apply.  Instead, emphasizing that “ERISA principles give primacy to written plan documents, requiring courts to enforce unambiguous terms as written,” the Court held that a plaintiff asserting an ERISA-estoppel claim must show:

1) conduct or language amounting to a representation of material fact;

2) awareness of the true facts by the defendant;

3) intent by the defendant that the representation be acted upon;

4) unawareness of the true facts by the plaintiff;

5) detrimental and justifiable reliance by the plaintiff; plus

6) a written representation;

7) plan provisions which, although unambiguous, did not allow for individual calculation of benefits; and

8) extraordinary circumstances.

In concluding that Higgins could not satisfy that standard, the Court pointed out that Higgins failed to plausibly allege that Lincoln Electric knew the true facts and intended to deceive him, and that, because Higgins had access to the plan documents that clearly established a $60,000 yearly cap on LTD benefits, reliance on the contradictory form was unreasonable as a matter of law.

In sum, although a plaintiff might argue that the equities point in a different direction, in Higgins, the Sixth Circuit reminded plaintiffs of the difficulties of establishing a right to estoppel in the face of unambiguous plan language.

If you have any questions about this ruling, please contact Olivia L. Southam or any member of the Frantz Ward Litigation practice group.