Palen v. KMart Corp., 2000 U.S. App. LEXIS 10780 (6^th Cir. May 9, 2000) (unpublished)- This court reversed the district court's summary judgment in favor of Kmart.  The Sixth Circuit stated that Kmart, as an ERISA fiduciary, owed a duty to communicate all material information regarding a beneficiary's plans, even if the request is vague or incomplete. That the beneficiary already knows details about the plans, or the fiduciary has previously informed the beneficiary of them, is irrelevant to the fiduciary's duty of disclosure.

Here, Andrew Danieli, upon leaving his company for a new position, inquired about continuing his benefits, without distinguishing between medical insurance coverage (which the employer also provided) and life insurance coverage.  When an answer was not readily available, his girlfriend, Cecilia Palen, later made several similarly vague inquiries about Mr. Danieli's benefits.  When Mr. Danieli fell ill, Ms. Palen again inquired, only then KMart informed her that the deadline for conversion had passed.  This court found that Kmart breached its duty of disclosure when it responded to Ms. Palen's inquiries by providing information about health insurance only, without a word about continuation of Mr. Danieli's life insurance.