ERISA And Limitations

Statute of Limitations issues are not usually seen in ERISA cases, but here is one.  This is a 2019, opinion from the Southern District of Texas, Houston Division.  It is styled, Cynthia Sternberg v. Metlife Insurance Company.

This case is currently before the Court on a Rule 12(b)(6) Motion to Dismiss filed by Metlife.  The Court granted the motion.

Sternberg filed for short term disability (STD) benefits from her employers claims administrator.  The STD benefits were granted.  Metlife is the claim administrator and it issued the group policy that funds the benefits under the Plan.  Sternberg later, filed for long term disability (LTD) benefits.  The claim for LTD was denied.

Sternberg timely appealed Metlife’s denial of LTD beneifts and the denial decision was upheld on June 5, 2015.  Sternberg filed this lawsuit on May 1, 2019.

To defeat a Rule 12(b)(6) motion, a plaintiff must plead enough facts to state a claim to relief that is plausible on its face.

The parties to a Plan can agree not only to the length of the applicable limitations period but also to when the limitations period will begin to run.  The principle that contractual limitations provisions should be enforced as written is especially appropriate in an ERISA plan because employers have large leeway to design disability and other welfare plans as they see fit.

Metlife argues that this action is time-barred by the Plan’s limitations period.  The Plan provides that a legal action on a claim may only be brought against Metlife during a certain period.  This period begins 60 days after the date Proof is filed and ends 3 years after the date such Proof is required.  The Plan required Plaintiff to submit Proof to Metlife not later than 90 days after the date of loss.   The Plan also contains an Elimination Period beginning on the day the claimant becomes disabled and continuing for 180 days or the short-term disability benefit period, whichever is greater.

Sternberg became disabled on September 10, 2013.  It is unclear when Sternberg submitted the required Proof to Metlife, so the Court is unable to determine when the limitations period began to run.  Metlife argues that the latest possible date Proof could be required under the Plan was June 9, 2014 — 90 days after the conclusion of the 180-day Elimination Period.  Metlife argues that Sternberg’s right to sue it under the Plan therefore expired, at the latest, on June 9, 2017.  Sternberg argues that the limitations period began to run on June 5, 2015, when Metlife upheld termination of her claim.  But Sternberg cites nothing in the Plan that would permit measuring the running of limitations from this date.  The Court is persuaded by Metlife’s argument that the limitations period expired no later than June 9, 2017.  Moreover, even if the three-year limitations period began to run when Metlife upheld termination of Sternberg’s claim on June 5, 2015, Sternberg’s claim is still time-barred because Sternberg did not file this action until May 1, 2019.  Sternberg does not argue that the limitations period in the Plan is unreasonable, and the U.S. Supreme Court has held that a similar contractual limitations period in an ERISA plan was enforceable.  Sternberg’s claim against Metlife is therefore time-barred by the Plan’s limitations period.

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