Young v. Washington Gas Light Co., 206 F.3d 1200 (D.C. Cir. 2000)-Young and other former supervisors or managers sued their former employer, Washington Gas Light Co., when, after their retirement, it offered a "voluntary separation incentive program" (the "Window Program").  The Window Program was a one-time opportunity to receive specified additional benefits for leaving the company.  Young alleged that the company breached its fiduciary duties under ERISA by failing to disclose, before their retirement, that the company was considering implementation of the Window Program.  (In fact, the company had explicitly denied to the employees that it was considering any type of new retirement incentive program.)  Young asserted that a duty to disclose arose both under the original plan and, alternatively, under the new Window Program as an ERISA plan itself.

This court affirmed the district court's dismissal for lack of subject matter jurisdiction based on its finding that Young stated no valid claim under ERISA.  This court first denied Young's claim that the Window Program was an ERISA plan.  The court noted that under the test of what constitutes an ERISA "plan" set out in Fort Halifax Packing Co. v. Coyne, 482 U.S. 1, 7 n.5, (1987), a "one-time lump-sum payment triggered by a single event" lacks the characteristic of ongoing administration characteristic of an ERISA plan. Here, the Window Program was such a one-time payment.

Also lacking merit was Young's argument that Washington Gas breached its fiduciary duty under the general retirement plan by failing to inform him and the other appellants that it was considering implementation of the Window Program.  The determinative issue here was that in contrast to other cases in which the Sponsor alters or terminates a plan, the Window Program did not replace, amend, or supplement Washington Gas's ERISA retirement plan; it merely created one-time benefits in addition to, and independent of, those to which the company's ERISA retirement plan entitles its employees.

Thus, ERISA imposes no obligation on a fiduciary to disclose information outside of or unrelated to the plan even if an employee might consider that information important to his decision to retire.