In a contentious legal battle over retirement benefits, the plaintiffs have lost their appeal to claim proceeds from a 401(k) plan governed by federal law. On June 12, 2024, Amy Fisher and others filed a complaint in the Court of Appeal of the State of California, Third Appellate District against Ava Landers.
The plaintiffs—Amy Fisher, Kim Ridgway, David Ide, and Samantha Ide—challenged a trial court decision that awarded all proceeds from a retirement benefits plan to defendant Ava Landers. The benefits plan in question is covered by the Employee Retirement Income Security Act of 1974 (ERISA). According to the trial court's findings, David Ide (a different individual than plaintiff David Ide) was a participant in Pacific Gas & Electric’s retirement savings plan. During his employment and until his death, he did not obtain spousal consent from Landers to designate another beneficiary for his 401(k) plan. Consequently, under ERISA’s provisions and relevant case law such as Carmona v. Carmona (9th Cir. 2010), the court concluded that state law claims were preempted by ERISA.
The plaintiffs argued that because Landers had already received the disbursement from the 401(k) plan, ERISA should not apply to their state law claims. However, they failed to provide an adequate record for review. The appellate court emphasized that it is fundamental for appellants to demonstrate error based on the record presented. Without sufficient documentation—including the specific causes of action or evidence heard at trial—the appellate court could not assess whether any unique factual circumstances might allow state law claims to avoid ERISA preemption.
ERISA mandates certain disbursements be made to spouses unless explicitly waived and includes a broad preemption clause overriding conflicting state laws. Plaintiffs’ reliance on cases allowing post-distribution claims did not sway the court due to insufficient records detailing how funds were disbursed or if any marital agreements existed.
Ultimately, the appellate court affirmed the trial court’s judgment in favor of Ava Landers and ruled that plaintiffs must pay costs on appeal.
Representing this case were attorneys whose names are not specified in this document summary. The presiding judges included Acting Presiding Justice Robie and Justices Duarte and Wiseman. The case identification number is C096204.