Establishing the Retirement Plans

Med-Legal Associates, Inc., based in Los Angeles, acted as the sponsor and administrator of two employee benefit plans: the MLA Defined Benefit Pension Plan (established in 2013) and the MLA Money Purchase Pension Plan (effective from 2017). These plans were created to provide retirement benefits to employees other than the company’s owner and spouse. Annual contributions were made and calculated by an enrolled actuary in accordance with IRS standards. Both plans included ERISA-compliant anti-alienation provisions explicitly barring creditors from accessing plan funds.

Conflict Over Creditor Claims

In 2017, defendants Bruce E. Fishman, M.D. and his professional corporation obtained a civil judgment against Med-Legal Associates. Two years later, they began efforts to enforce the judgment by attempting to levy and garnish funds from the MLA pension plans. Med-Legal objected, asserting that the retirement plan assets were protected by ERISA and the plans’ governing documents. The company argued that these attempts violated federal law and endangered benefits meant for multiple covered employees.

Risk to Fiduciary Integrity and Beneficiaries

Med-Legal claimed that the defendants’ collection efforts placed the company in a compromised position as plan fiduciary. If the levies were allowed to proce