In Packaging Corporation of America Thrift Plan for Hourly Employees v. Langdon, decided on 2 February 2026, the US Court of Appeals for the Seventh Circuit considered an attempted beneficiary change after divorce. The participant’s fax expressed his wish to remove his former spouse, but he had not followed the plan’s specified telephone or online process.
The court found that the participant had not satisfied the substantial compliance test and reversed the lower court’s judgment. The original opinion, reviewed for this item, is the date source; SHRM’s later coverage was published on 15 April. The decision concerns the facts and procedures of this particular ERISA plan.
Make the required action clear For employers and administrators, the case supports a practical review of beneficiary-change communications. Employees should be able to identify the required channel and the action they must complete. A general instruction to keep details current may leave uncertainty about the actual process.
This editor recommends checking whether the instructions used in employee communications match the governing documents and the administrative system. The review should include information given during significant life events, when employees may be changing several benefits at once.
Check what the record confirms A change to marital status and a change to beneficiary designation are different administrative actions. Teams should make clear which action a confirmation records. Employees should not have to infer from an unrelated update that their intended beneficiary change is complete.
The operational review can examine how incomplete or incorrectly submitted requests are handled and how employees obtain further instructions. Documenting that process helps staff explain the next step consistently without improvising a different procedure.
Preserve the legal scope The opinion should not be treated as a rule that every fax is invalid, or that all plans use the same procedure. Its significance lies in the relationship between the participant’s action and the governing terms applied by the court. Other circumstances require their own assessment.
The employer’s practical response is to make the prescribed process understandable and the resulting records clear. Beneficiary administration is often a small part of everyday benefits work, but uncertainty can become consequential when benefits fall due. Clear instructions and confirmation processes deserve attention before a dispute arises.
Sources: Source de référence [1]
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