Packaging Corporation of America Thrift Plan for Hourly Employees v. Langdon

In a lawsuit involving a company retirement plan, the parties disputed whether the decedent plan holder had removed his former spouse as the primary plan beneficiary prior to his death. The district court concluded that the decedent had successfully removed his ex-spouse as the beneficiary of the retirement account and entered summary judgment on that issue sua sponte. The Seventh Circuit reversed, finding that the decedent’s estate did not satisfy the substantial compliance test. (LEE and KOLAR, concurring)