Nationwide Mutual Insurance Co. v. Darden

Summary

Justice Souter delivered the unanimous opinion holding that ERISA's definition of “employee” incorporates traditional common-law agency principles. The Court rejected the Fourth Circuit's alternative test based on expectations of benefits, reliance, and bargaining power, finding it inconsistent with statutory interpretation principles and insufficiently predictable. Because the Fourth Circuit had not decided whether Darden qualified as an employee under the proper test, the Court reversed and remanded without resolving his employment status. There were no separate opinions.