Hammell v. Pilot Products, Inc.

CourtCourt of Appeals for the Second Circuit
DecidedMarch 3, 2026
Docket24-3283
StatusUnpublished

This text of Hammell v. Pilot Products, Inc. (Hammell v. Pilot Products, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hammell v. Pilot Products, Inc., (2d Cir. 2026).

Opinion

24-3283 (L) Hammell v. Pilot Products, Inc.

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 3rd day of March, two thousand twenty-six.

PRESENT: JOSEPH F. BIANCO, MYRNA PÉREZ, MARIA ARAÚJO KAHN, Circuit Judges. ____________________________________________

ELIZABETH HAMMELL, on behalf of herself and as executrix and trustee of the ESTATES OF HERBERT AND MARCIA HEBEL, as well as on behalf of the PILOT PRODUCTS, INC. DEFINED BENEFIT PENSION PLAN,

Plaintiff-Counter-Defendant-Appellee-Cross-Appellant,

v. 24-3283-cv (Lead) 25-29-cv (XAP) PILOT PRODUCTS, INC. DEFINED BENEFIT PENSION PLAN, PILOT PRODUCTS, INC., CAROLYN HEBEL,

Defendants-Counter-Claimants-Appellants-Cross-Appellees. ____________________________________________

FOR PLAINTIFF-COUNTER- DANA E. BERKOWITZ (Natalie A. Willis, on DEFENDANT-APPELLEE-CROSS- the brief), King and Spalding LLP, New APPELLANT: York, New York and Atlanta, GA. FOR DEFENDANTS-COUNTER- JONATHAN G. ROSE, DLA Piper, LLP, CLAIMANTS-APPELLANTS-CROSS- Washington, D.C. APPELLEES:

Appeal from a judgment of the United States District Court for the Eastern District of New

York (Brian M. Cogan, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the amended judgment of the district court, entered on January 15, 2025, is

AFFIRMED.

Defendants-Counter-Claimants-Appellants-Cross-Appellees Pilot Products, Inc. (“Pilot”),

Pilot’s Defined Benefit Pension Plan, and Carolyn Hebel (collectively, “Appellants”) appeal from

the district court’s amended judgment in favor of Plaintiff-Counter-Defendant-Appellee-Cross-

Appellant Elizabeth Hammell, on behalf of herself as executrix and trustee of the Estates of Herbert

and Marcia Hebel, as well as on behalf of Pilot’s Defined Benefit Pension Plan, on the claim for

breach of the fiduciary duty of care, pursuant to the Employee Retirement Income Security Act of

1974 (“ERISA”), 29 U.S.C. §§ 1001 et seq. 1 Elizabeth cross-appeals the district court’s amended

judgment, to the extent that it found in favor of Appellants with respect to her ERISA claim for a

breach of the fiduciary duty of loyalty. 2 We assume the parties’ familiarity with the underlying

facts, procedural history, and issues on appeal, to which we refer only as necessary to explain our

decision to affirm.

1 In the interest of clarity, we refer to members of the Hebel family by their first names. 2 In her brief, Elizabeth does not challenge the district court’s determination that her conversion claim was preempted by ERISA, and thus has abandoned any such challenge on appeal. See LoSacco v. City of Middletown, 71 F.3d 88, 92–93 (2d Cir. 1995). Similarly, if her arguments on appeal are rejected regarding the claim for breach of the fiduciary duty of care, Carolyn does not separately challenge the district court’s award to Elizabeth of attorneys’ fees and costs, pursuant to 29 U.S.C. § 1132(g)(1). 2 This appeal arises from a dispute regarding the management of a pension plan for Pilot (the

“Plan”), a now-dissolved manufacturing company. In 1947, Herbert and Marcia founded Pilot

and, in 1986, Herbert established the Plan for Pilot’s employees. For many years, Herbert, Marcia,

and their daughters, Elizabeth and Carolyn, served as directors of Pilot and trustees of the Plan.

Herbert, Marcia, and Carolyn were also participants in the Plan. Upon Herbert’s death in 2011,

litigation ensued about his will and control of Pilot, with Carolyn on one side, and Marcia and

Elizabeth on the other. In 2014, they resolved those lawsuits through a settlement agreement, in

which Marcia and Elizabeth resigned from their roles at Pilot and as trustees of the Plan, and also

sold their Pilot shares to Carolyn. Pursuant to the settlement agreement, Carolyn became the sole

officer and shareholder of Pilot, as well as the sole trustee of the Plan. In exchange, Carolyn

agreed to pay $1 to Elizabeth, $275,000 to Herbert’s estate, and $1,000 per week to Marcia for the

rest of her life. It was further agreed that Pilot would indemnify Marcia and Elizabeth for any

liabilities of Pilot, which would include liabilities of the Plan.

In 2018, Carolyn initiated the termination process for the Plan with the Internal Revenue

Service (“IRS”) and the Pension Benefit Guarantee Corporation (“PBGC”). However, the Plan

was significantly underfunded, prompting Carolyn to seek an extension to distribute the Plan’s

assets. On October 25, 2019, Carolyn, through her attorney, sent a letter to the attorney for

Elizabeth and Marcia, informing them that the Plan was in the process of being terminated, that it

was underfunded, and that “[a]pproximately $1,500,000 needs to come” from Elizabeth and

Marcia to correct the underfunding. Joint App’x at 1263. The letter also attached election forms

that, if completed, would have permitted Marcia to elect to receive her and her deceased husband’s

benefits in a lump sum. With respect to the forms, the letter stated, “I have attached the Statement

3 of Rights and Alternatives and Election Form for Marcia Hebel and the Beneficiary of Herbert

Hebel, for you and your clients to review and make a determination in that regard.” Id. Although

not noted in the letter or the forms, Marcia’s election of the lump-sum benefits would have resulted

in a substantially larger dollar amount of benefits to her than would otherwise result from the

default annuity if no such election was made before her death.

Over the next couple of months, attorneys for the parties exchanged correspondence

regarding the alleged responsibility of Elizabeth and Marcia to fund the Plan, with no resolution.

In the correspondence, Elizabeth’s attorney requested the “insurer information” for the annuity

option because Marcia and Elizabeth lacked the information needed “to make an informed

election.” Id. at 1511. Moreover, in December 2019, Carolyn failed to pay Marcia’s annual Plan

benefit of $349,910 and, instead, transferred that sum to the client trust account held by her

attorney’s firm. In April 2020, Marcia died from COVID-19. Because Marcia never completed

the election forms, the Plan made a final distribution to Marcia’s estate in the amount of $87,477.77,

representing payments under a hypothetical annuity for 2020, as well as the $349,910 owed as an

annual benefit to Marcia from 2019, for a total of $437,387.77. In February 2021, Carolyn located

an additional $293,465 in Plan accounts and distributed that money to herself.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Varity Corp. v. Howe
516 U.S. 489 (Supreme Court, 1996)
CIGNA Corp. v. Amara
131 S. Ct. 1866 (Supreme Court, 2011)
Donovan v. Bierwirth
680 F.2d 263 (Second Circuit, 1982)
Chao v. Merino
452 F.3d 174 (Second Circuit, 2006)
Slupinski v. First Unum Life Insurance
554 F.3d 38 (Second Circuit, 2009)
Pfahler v. National Latex Products Co.
517 F.3d 816 (Sixth Circuit, 2007)
Spokeo, Inc. v. Robins
578 U.S. 330 (Supreme Court, 2016)
Thole v. U. S. Bank N. A.
590 U.S. 538 (Supreme Court, 2020)
SM Kids, LLC v. Google LLC
963 F.3d 206 (Second Circuit, 2020)
Layaou v. Xerox Corp.
238 F.3d 205 (Second Circuit, 2001)
Devlin v. Empire Blue Cross & Blue Shield
274 F.3d 76 (Second Circuit, 2001)
Leyda v. AlliedSignal, Inc.
322 F.3d 199 (Second Circuit, 2003)
Henry v. Champlain Enterprises, Inc.
445 F.3d 610 (Second Circuit, 2006)
Mantena v. Johnson
809 F.3d 721 (Second Circuit, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Hammell v. Pilot Products, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/hammell-v-pilot-products-inc-ca2-2026.