Elizabeth Wilson Vaughan is an associate in the ERISA Litigation Group. Her practice experience includes assisting with the defense of 401(k)/employer stock-drop class actions and claims against third-party administrators, as well as individual ERISA claims for short-term disability benefits, long-term disability benefits and life insurance benefits.
In 2010, Ms. Vaughan graduated, summa cum laude, from the University of Tennessee College of Law. She was a member of the National Moot Court team and received the Susan B. Devitt National Moot Court Award in recognition of her work on the team. Ms. Vaughan won the prestigious Ray H. Jenkins Trial Competition and the Advocates’ Prize Moot Court Competition in her third year of law school. In honor of her overall moot court experience, Ms. Vaughan also won the Judge James M. Haynes Prize and the McClung Medal. She was elected to the Order of the Coif and the Order of the Barristers. In 2007, Ms. Vaughan graduated, summa cum laude, with her Bachelor of Arts in college scholars, with a concentration in public policy and new destination Latino immigration from the University of Tennessee, Knoxville, where she was elected to Phi Beta Kappa and named a Torchbearer, the highest award given by the university.
- Served as co-chair for bench trial, resulting in favorable verdict for client The Prudential Insurance Company of America, in case involving claims for ERISA-governed life insurance benefits. Delgado v. Prudential Ins. Co. of Am. et al., No. 11–cv–20520–KMM, 2012 WL 668147 (S.D. Fla. Feb. 29, 2012) (order following bench trial).
This advisory discusses the Supreme Court’s recent decision in US Airways v. McCutchen—a decision that can best be described as a half-victory for sponsors and administrators of ERISA-governed plans. In a 5-4 ruling that “has two parts, one favoring US Airways, the other McCutchen,” the Supreme Court held that, in an action brought under Section 502(a)(3) of ERISA based on an equitable lien by agreement, the terms of the ERISA plan govern. Neither general principles of unjust enrichment nor specific doctrines reflecting those principles (such as double-recovery or common-fund rules) can override the applicable contract. However, if the plan terms do not proscribe who will bear the costs of recovery, the common-fund doctrine provides the best indication of the parties’ intent. Though the Supreme Court did not allow equitable defenses to eviscerate and override plan terms, this decision reinforces the importance of ensuring plan terms are sufficiently clear and specific.
April 18, 2013
“Employer Stock-Drop Cases: The Second Circuit Weighs In,” Employee Benefit Plan Review, Vol. 6, No. 8 (Aspen Publishers, Feb. 2012).
"Estoppel as a Basis for Recovery for Misrepresentation," in the treatise ERISA Litigation, published by the Bureau of National Affairs, 2012 Chapter Supplement.
“Public Policy and New Destination Latino Immigration,” The Baker Center Journal of Applied Public Policy, Vol. II, No. 1, Spring 2008.