Did Varity's deception violate ERISA-imposed fiduciary duties?
Yes. In misleading Howe and the other employees, Varity violated the fiduciary obligations that ERISA Section 404 imposes upon plan administrators. To participate knowingly and significantly in deceiving a plan's beneficiaries in order to save the employer money at the beneficiaries' expense, is not to act "solely in the interest of the participants and beneficiaries.". There is no basis in the statute for any special interpretation that might insulate Varity from the legal consequences of the kind of conduct that often creates liability even among strangers.
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______ theories explain motivation as the needs that people seek to satisfy.
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