MetLife Failed to State Deadline for Filing ERISA Lawsuit in Denial Letter – Court Rejects Statute of Limitations Defense
Joining two other federal appellate courts, the First Circuit Court of Appeals issued a ruling “that ERISA requires a plan administrator in its denial of benefits letter to inform a claimant of not only his right to bring a civil action, but also the plan-imposed time limit for doing so.” The case was Santana-Diaz v. Metropolitan Life Ins. Co., 2016 WL 963830 (1st Cir. March 14, 2016). Because MetLife failed to state the deadline for filing suit in its decision letter, the court held that the disabled plaintiff who was seeking disability benefits under his employer’s ERISA disability insurance plan would not have his lawsuit dismissed for being late.
Important Ruling – ERISA Plans Often Change Deadlines Without Employees Knowing About It
This ruling is significant, because ERISA (the federal law that regulates employee benefits) allows employers and plan administrators to write plans with a different lawsuit deadlines than the statute of limitations contained in actual statutes. Many employees have no idea that their company’s ERISA disability plan changes the limitations period, nearly always shortening it. Some plans have language that requires a person to read two or three different sections together to calculate the deadline. The court’s ruling was aimed solely at benefit plans which contain language changing the statute of limitations applied under the law.
Dept. of Labor Regulations Basis for Ruling
The First Circuit based its decision on the U.S. Department of Labor’s ERISA claim regulations which require an ERISA disability plan administrator like MetLife to specifically provide “written or electronic notification of any adverse benefit determination” that includes a “description of the plan’s review procedures and the time limits applicable to such procedures, including a statement of the claimant’s right to bring a civil action.” 29 C.F.R. § 2560.503-1(g)(1)(iv). The court held that the defective denial letter as “per se prejudicial” to the claimant. More importantly, the court acknowledged that other documents like the plan document or summary plan description may contain language explaining the limitations period, but that does not trump the federal regulation which requires notification in the decision letter from the plan administrator.
Court Joins Two Other Courts
The disability insurance company took the position that the “time limits” language only applied to pre-suit appeals, but the First Circuit Court rejected that argument, citing to decisions from two other appellate courts – the Third and Sixth Circuit Courts of Appeal – which also ruled that disability plan administrators must include the deadline for filing suit in decision letters. Mirza v. Insurance Administrator of America, Inc., 800 F.3d 129 (3d Cir.2015) and Moyer v. Metropolitan Life Insurance Co., 762 F.3d 503 (6th Cir.2014).