Pronti v. CNA Financial Corp.
Plaintiff Thomas J. Pronti sued CNA Financial Corporation and CNA Retirement Plan (collectively, "Defendants") alleging misrepresentations regarding his pension benefits. Pronti claimed his benefits were wrongfully calculated because his prior service with Continental Insurance Company was not credited under the CNA Plan, despite alleged representations to the contrary. Pronti brought claims for benefits, breach of fiduciary duty, breach of contract, and estoppel. The Court granted Defendants' motion to dismiss the breach of fiduciary duty claim, finding it duplicated the claim for benefits under ERISA, and the breach of contract claim, finding it preempted by ERISA. However, the Court denied Defendants' motion to dismiss the promissory estoppel claim, concluding that Pronti had sufficiently alleged a promise, reliance, injury, injustice, and "extraordinary circumstances" under ERISA's federal common law.