## Facts

- Shirley Edwards worked as A.H. Cornell’s Director of Human Resources and participated in the company’s ERISA-governed group health plan.
- Near the end of her employment, Edwards alleged she discovered plan-related misconduct, including discriminatory administration, misrepresentations about coverage costs to discourage enrollment, and enrollment of non-citizens using false identifying information.
- Edwards alleged she made unsolicited internal complaints to management about these alleged ERISA violations.
- Edwards alleged she was terminated shortly after making these internal complaints.
- Edwards sued, claiming retaliation in violation of ERISA § 510, which prohibits adverse action against a participant or beneficiary for giving information or testifying in an “inquiry or proceeding” relating to ERISA.

## Issues

1. Whether ERISA § 510 protects an employee from retaliation for making unsolicited internal complaints to management about alleged ERISA violations.
2. Whether “giv[ing] information ... in any inquiry or proceeding” in § 510 includes voluntary internal reporting absent a request for information or a formal process.

## Decision

- The Third Circuit affirmed dismissal under Rule 12(b)(6).
- The court held that unsolicited internal complaints to management are not protected activity under ERISA § 510.
- Because Edwards did not allege her statements were made in response to an inquiry or within a formal proceeding, her complaint failed to state a plausible § 510 claim.

## Legal Principles

- ERISA § 510 protects employees only when they give information or testify in connection with an “inquiry or proceeding” relating to ERISA.
- An “inquiry” contemplates a request for information; voluntary, unsolicited internal complaints do not qualify.
- A “proceeding” implies a formal administrative or legal process; informal internal reporting alone is insufficient.
- Courts may not expand § 510’s anti-retaliation scope beyond its statutory text based solely on ERISA’s remedial purposes.

## Conclusion

The Third Circuit held that ERISA § 510’s anti-retaliation protection does not extend to an employee’s unsolicited internal complaints to management; protected conduct requires giving information or testimony tied to an actual inquiry or formal proceeding.


Edwards v. A.H. Cornell & Son, Inc., 610 F.3d 217 (3d Cir. 2010)