Hamilton v. Allen-Bradley, 217 F.3d 1321 (11^th Cir. 2000)-When Hamilton suspected that her inability to work due to carpal tunnel syndrome might entitle her to long-term disability benefits, she inquired with the human resources director at her company, as procedure required.  Lee, the director, allegedly stated on several occasions that Hamilton did not qualify, refused to provide Hamilton with a claim form, and failed to inform Hamilton of the identity of the company's disability plan insurer (UNUM).  This court reversed the district court, concluding that the human resources director (and therefore Allen-Bradley) did qualify as a plan administrator and fiduciary, and that Hamilton stated valid claims for breach of fiduciary duty.

Although the plan booklet stated the claimant must make the claims to UNUM, the fact that the company required claims to go through its human resources department "places Allen in sufficient control over the process to qualify as the plan administrator notwithstanding the language of the plan booklet." See Law v. Ernst & Young, 956 F.2d 364, 373-74 (1^st Cir. 1992).  As to the question of whether Hamilton could maintain a private cause of action for fiduciary breach, this court said yes, citing Varity Corp. v. Howe, 516 U.S. 489, 511-512, (1996), which found that 29 U.S.C. § 1109(a) does not function "as a limitation of rights, given the statute's overall purpose in benefiting injured beneficiaries." Finally, this court did agree with Allen-Bradley that it did not have a fiduciary duty under ERISA to provide Hamilton with claim forms where Hamilton failed to submit a written request for them. Allen's failure to disclose information, however, would clearly constitute a breach of a fiduciary duty.