Nationwide Mutual Insurance Company, et al. v. Robert T. Darden (503 U.S. 318)

U.S. Supreme Court · decided March 24, 1992 · Supreme Court Database (Spaeth)

Citation
503 U.S. 318 · 112 S. Ct. 1344
Decided
March 24, 1992
Term
October Term 1991
Vote
9–0
Majority author
Justice Souter
Issue area
Economic Activity
Disposition
Reversed and remanded
Outcome
Petitioning party won
Ideological direction
Conservative

Opinion excerpt

Justice Souter delivered the opinion of the Court. In this case we construe the term “employee” as it appears in § 3(6) of the Employee Retirement Income Security Act of 1974 (ERISA), 88 Stat. 834, 29 U. S. C. § 1002(6), and read it to incorporate traditional agency law criteria for identifying master-servant relationships. I From 1962 through 1980, respondent Robert Darden operated an insurance agency according to the terms of several contracts he signed with petitioners Nationwide Mutual Insurance Co. et al. Darden promised to sell only Nationwide insurance policies, and, in exchange, Nationwide agreed to pay him commissions on his sales and enroll him in a company retirement scheme called the “Agent’s Security Compensation Plan” (Plan). The Plan consisted of two different programs: the “Deferred Compensation Incentive Credit Plan,” under which Nationwide annually credited an agent’s retirement account with a sum based on his business performance, and the “Extended Earnings Plan,” under which Nationwide paid an agent, upon retirement or termination, a sum equal to the total of his policy renewal fees for the previous 12 months. Such were the contractual terms, however, that Darden would forfeit his entitlement to the Plan’s benefits if, within a year of his termination and 25 miles of his prior business location, he sold insurance for Nationwide’s competitors. The contracts…

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