Section 502(a)(1) permits civil lawsuits to be brought by participants or beneficiaries of an employee benefits plan. The Tenth Circuit Court of Appeals held in Chastain v. AT&T, 558 F.3d 1177 (10th Cir. 2009), that retired employees and beneficiaries of an AT&T employee benefit plan did not have standing to sue AT&T under Section 502(a)(1) for benefits under the plan after AT&T transferred the employee benefit plan to a spin-off entity. The court found that since the retired employees were no longer participants or benefits any employee benefits plan of AT&T as a result of the transfer of the plan to the spin-off entity, the employees did not have standing to sue AT&T under Section 502(a)(1).
The court articulated the rule that when a business entity creates a spin-off and transfers its employee benefit plans to that spin-off, employees covered under the spin-off plan cannot sue the original business entity under Section 502(a)(1)(B).