Curtis T. Pedersen, et al. v. Kinder Morgan Inc, et al.

District Court, S.D. Texas·Decided August 10, 2026·No. 4:21-cv-03590·Unknown

Opinion

UNITED STATES DISTRICT COURT August 10, 2026 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION

CURTIS T PEDERSEN, et al., § § Plaintiffs, § § VS. § CIVIL ACTION NO. 4:21-CV-03590 § KINDER MORGAN INC, et al., § § Defendants. §

MEMORANDUM & ORDER Before the Court are Plaintiffs’ Motion for Equitable Relief (ECF No. 245), Magistrate Judge Ho’s Memorandum and Recommendations (ECF No. 254) (“M&R”), and Plaintiffs’ Objections to the M&R (ECF No. 256). Defendants have not objected to the M&R, though they have preserved their right to appeal this Court’s prior findings on liability, and responded in opposition to Plaintiffs’ objections. The Court has reviewed all the relevant briefing and conducted a de novo review of the portions of the M&R to which Plaintiffs objected.1 See 28 U.S.C. § 636(b)(1)(C); FED. R. CIV. PRO. 72(b)(3). For the reasons that follow, Plaintiffs’ objections are

1 Defendants acknowledge Rule 72’s mandate that this Court “determine de novo any part of the magistrate judge’s disposition that has been properly objected to.” FED. R. CIV. PRO. 27(b)(3). However, they fault Plaintiffs’ objections for “recycl[ing] arguments Judge Ho already considered and rejected.” ECF No. 260 at 1. The Court finds no legal support for the notion that a party may not re-urge arguments already considered by the magistrate judge in its objections. Moreover, the fact that Judge Ho “already considered” a given argument does not preclude this Court from reaching a different result. While the Court has the utmost respect for Judge Ho’s thorough consideration of the issues, this does not relieve the Court of its obligation to review her recommendations de novo. 1 / 18 SUSTAINED IN PART to the extent described below. The Motion for Equitable Relief is GRANTED IN PART and DENIED IN PART, as follows.2

I. Relief for the Benefit Accrual Disclosure Violations 1. With regard to the Benefit Accrual subclass, the Court previously found that Defendants violated ERISA § 102 by failing to understandably disclose the impact of the 2001 Coastal Transition Benefit formula’s use of an “uncapped” denominator in the fraction used to calculate retirement benefits on participants hired before age 35 in its Summary Plan Descriptions (“SPDs”). See Pedersen v. Kinder Morgan Inc., 742 F. Supp.3d 725, 745-47 (S.D. Tex. 2024). The SPDs failed to explain, in a manner calculated to be understood by an average participant, that employees hired prior to age 35 “do not earn the 2% of pay benefit promised in the SPD, but instead may earn as little as 1.33% of pay after a fraction

based on the years between their date of hire and age 65 is applied.” Id. at 745. This violation of § 102 “risk[ed] misleading participants who were hired before age 35 as to their total amount of accrued benefits.” Id. at 747. 2. Plaintiffs request that the Court provide “appropriate equitable relief” to the Benefit Accrual subclass under ERISA § 502(a)(3) in the form of reformation of the Coastal Transition Benefit formula, and, in the alternative, injunctive relief and equitable surcharge. The M&R recommends denying any type of equitable relief to the Benefit Accrual subclass.

2 The Court assumes the parties’ familiarity with the background of this case. A full discussion of the underlying facts can be found in this Court’s prior rulings and Judge Ho’s M&R. See Pedersen v. Kinder Morgan Inc., 622 F. Supp. 3d 520, 526-32 (S.D. Tex. 2022); Pedersen v. Kinder Morgan Inc., 345 F.R.D. 302, 308-12 (S.D. Tex. 2024); Pedersen v. Kinder Morgan Inc., 742 F. Supp. 3d 725, 731-37 (S.D. Tex. 2024); M&R at 2-9. The Court incorporates these previous discussions. 2 / 18 3. This Court SUSTAINS Plaintiffs’ objection to the M&R’s recommendation that the equitable remedy of reformation is not available to the Benefit Accrual subclass for the disclosure violations this Court found on Claim III of Plaintiffs’ Amended Complaint. 4. “Reformation requires a plaintiff to show either a mutual mistake of both parties or the

mistake of one party coupled with fraud or inequitable conduct by the other.” Lauga v. Applied Cleveland Holdings, Inc., 2018 WL 3495860, 13 at *3 (E.D. La. July 20, 2018). “A plaintiff must prove mistake and fraud by clear and convincing evidence.” Amara v. CIGNA Corp., 925 F. Supp. 2d 242, 252 (D. Conn. 2012), aff’d, 775 F.3d 510 (2d Cir. 2014). Here, there is no allegation of mutual mistake, so only fraud or inequitable conduct are at issue. 5. “Fraud has a broader meaning in equity [than at law] and intention to defraud or to misrepresent is not a necessary element.” Pearce v. Chrysler Grp. LLC Pension Plan, 893 F.3d 339, 348 (6th Cir. 2018) (quoting SEC v. Capital Gains Research Bureau, Inc., 375 U.S. 180, 193 (1963)). “Fraud. . . in the sense of a court of equity properly includes all acts,

omissions and concealments which involve a breach of legal or equitable duty, trust, or confidence, justly reposed, and are injurious to another, or by which an undue and unconscientious advantage is taken of another.” Id. (internal quotation marks omitted) (quoting Capital Gains Research Bureau, Inc., 375 U.S. at 193). 6. While the M&R acknowledges that “intention to defraud or to misrepresent is not a necessary element” of equitable fraud for the purposes of ordering reformation, it nonetheless concludes that reformation should not be available without proof that “Defendants engaged in some wrongdoing apart from the disclosure violation itself.” M&R at 14 (emphasis in original). The Court agrees with Plaintiffs that this requirement

3 / 18 overstates the necessary showing for equitable fraud and has the practical effect of imposing an intentional misconduct requirement. 7. The Sixth Circuit’s decision is Pearce, though not binding on this Court, is instructive. In Pearce, the Sixth Circuit described three relevant “guideposts” for assessing equitable

fraud. Pearce, 893 F.3d at 347. First, “whether a defendant had a ‘legal or equitable duty, trust, or confidence’” is “an important factor.” Id. Second, the defendant must have “obtained ‘an undue and unconscientious advantage’ or the plaintiff must have suffered an injury or both.” Id. Third, “reformation’s requirement of fraud or inequitable conduct roughly mirrors the fraud element of equitable estoppel.” Id. While the Sixth Circuit remanded to the district court to consider these factors in the first instance, it noted that the Defendant’s violation of § 102 of ERISA by failing to describe an exclusion in its SPD constituted a breach of its duty to the plaintiff. See also Singletary v. UPS, 828 F.3d 342, 348-49 (5th Cir. 2016) (holding that “[a]n incomplete SPD violates ‘§ 102 of ERISA and [is] also a fiduciary violation’” because plan sponsors have a “[d]uty of disclosure” under

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Curtis T. Pedersen, et al. v. Kinder Morgan Inc, et al., (S.D. Tex. 2026).

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