The District of Maryland granted the American Funds Distributors Inc.'s motion for summary judgment on an estate’s breach of contract action relating to the decedent’s participation in the Waldorf Ford Inc. Salary Deferral 401(k) Profit Sharing Plan. The court said that the breach of contract action is preempted by ERISA, and that, once converted to an ERISA claim, the estate’s claim fails as a matter of law.
Case: Retirement Benefits/Preemption (D. Md.)
Sept. 18, 2025, 7:54 PM UTC