DeBofsky Law is proud to announce a significant victory in Skowronski v. Briggs, Case No. 22-cv-7359. The firm successfully defended Sandra Jensen Briggs, a registered civil union partner who was sued by her late partner’s adult children after IBM paid her 401(k) retirement benefits following her partner’s death. On February 27, 2026, Judge John J. Tharp, Jr., of the U.S. District Court for the Northern District of Illinois granted motions to dismiss on behalf of Briggs and IBM.
Download the Skowronski v. Briggs Memorandum Opinion (February 27, 2026)
Skowronski v. Briggs: Case Overview
Steven Skowronski was an IBM employee and participant in the IBM 401(k) Plus Plan. In January 2020, he designated his two adult children and his romantic partner, Sandra Jensen Briggs, as equal beneficiaries of his 401(k) account. About one month later, Steven and Briggs entered into a registered civil union in McHenry County, Illinois.
Steven passed away on April 17, 2022. IBM, through its recordkeeper Fidelity, recognized Briggs as the surviving spouse under the federal Retirement Equity Act, a law added to ERISA to protect the retirement benefit rights of surviving spouses. IBM transferred the full account balance to Briggs.
Steven’s adult children filed a lawsuit arguing that a civil union partner does not qualify as a spouse under the terms of the Plan. They sought to recover two-thirds of the account balance. Both Briggs and IBM moved to dismiss.
Legal Challenge and Court Findings
The court applied de novo review, finding that the dispute turned on a question of law rather than plan administration. The central issue was whether the Plan’s definition of ‘spouse’ included civil union partners under Illinois law.
The IBM 401(k) Plus Plan defined spouse as ‘a person who, according to the marriage laws of the state of a participant’s residence, is the spouse of a participant.’ That definition directed the court to Illinois law, which provided a clear answer.
The Illinois Religious Freedom Protection and Civil Union Act states that ‘party to a civil union’ is included in any definition or use of the term ‘spouse’ as that term appears throughout the law (750 ILCS 75/20). Because Briggs and Steven entered into a registered civil union while residing in Illinois, Briggs qualified as his spouse under the terms of the Plan.
The court rejected the plaintiffs’ argument that federal definitions of ‘spouse’ should control. Under ERISA, plan language governs. The Plan specifically incorporated state law to define spouse, and Illinois law was unambiguous.
Impact of the Skowronski v. Briggs Ruling
This ruling reinforces a foundational principle of ERISA: plan documents control. When a plan references state law to define a term, that state law applies, even when federal definitions might differ.
While same-sex marriages are now federally recognized, registered civil unions remain relevant in many benefit contexts. This decision confirms that civil union partners in Illinois hold the same spousal rights as married partners when a plan’s language incorporates state law definitions.
The ruling will likely serve as persuasive authority in future disputes involving civil union partners and ERISA-governed benefit plans.
Shareholder Mark DeBofsky represented Sandra Jensen Briggs.
If you have questions about your rights as a beneficiary or surviving partner under an employer-sponsored retirement plan, contact DeBofsky Law today.