Dallas Fort Worth Insurance Lawyer Blog
Here is a 2020, case from the Southern District of Texas, Houston Division, that deals with life insurance wherein the life insurance plan is subject to the Employee Retirement Income Security Act (ERISA). The case is styled, Wagma Mina Huerta v. Metropolitan Life Insurance Company, et al.
This case, filed by Huerta , is an action pursuant to ERISA seeking equitable relief for alleged breaches of fiduciary duty by the Defendants related to the denial of life insurance coverage for the death of Huerta’s husband.
The opinion is lengthy but only a part will be discussed here. The factual background can be read in the opinion. In this case, MetLife had filed a motion to dismiss pursuant to Federal Rule 12(b)(6), which allows dismissal of an action whenever the complaint, on its face, fails to state a claim upon which relief can be granted. United States, 5th Circuit case law states that when considering a motion to dismiss, the court may consider, in addition to the complaint itself, “any documents attached to the motion to dismiss that are central to the claim and referenced by the complaint.” This is discussed in the 2010, opinion, Lone Star Fund V (U.S.), L.P. v. Barclays Bank PLC. When a defendant attaches such documents, it “merely assists the plaintiff in establishing the basis of the suit and the court in making the elementary determination of whether a claim has been stated.”
Other case law points out that the court should construe the allegations in the complaint favorably to the pleader and accept as true all well-pleaded facts. A complaint need not contain “detailed factual allegations” but must include sufficient facts to indicate the plausibility of the claims asserted, raising the right to relief above the speculative level. According to the 2007, United States Supreme Court opinion Bell Atlantic Corp. v. Twombly, and the 2009, opinion Ashcroft v. Iqbal, plausibility means that the factual content “allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” A plaintiff must provide more “than labels and conclusions” or “a formulaic recitation of the elements of the cause of action.” In other words, the factual allegations must allow for an inference of “more than a sheer possibility that a defendant has acted unlawfully.”
In this particular case, the Court granted MetLife’s motion but allowed time for Huerta to amend her complaint to thoroughly address issues discussed by the Court in its opinion.