Hakim v. Accenture United States Pension Plan

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in plaintiff-former employee’s ERISA action alleging that defendant had failed to give proper notice of amendment to defendant’s pension plan that resulted in reduction of plaintiff’s future benefit accrual where, after amendment had gone into effect, plaintiff had signed general release of all claims against defendant in exchange for severance benefits. Instant contested pension claim was outside realm of ERISA’s anti-alienation provision, and as such, was barred pursuant to terms of general release under Howell, 633 F.3d 552, where plaintiff had constructive notice of his pension claim at time he signed release.