ERISA-Fifth Circuit Rules That Suit For Long-Term Disability Benefits Was Filed Too Late

In White v. Metropolitan Life Insurance Company, No. 10-30707 (5th Cir. 2011), the plaintiff had brought suit under ERISA challenging the decision of the defendant, Metropolitan Life Insurance Company (“Metropolitan”), to deny her claim for long-term disability benefits, under the terms of a plan subject to ERISA (the “Plan”). The district court granted summary judgment in favor of Metropolitan. One issue on appeal-did the plaintiff initially file her suit on a timely basis? Here is what the Fifth Circuit Court said.

The terms of the Plan provide that no legal action may be filed “more than three years after proof of Disability must be filed. This will not apply if the law in the area where you live allows a longer period of time to file proof of Disability.” In this case, the plaintiff’s suit was not filed within this time period, and the plaintiff does not identify any local law (here Louisiana) which allows a longer period of time for filing proof of disability. Therefore, Court concluded that the plaintiff’s suit was filed too late. The Court cited Harris Methodist Fort Worth v. Sales Support Servs., Inc. Empl. Health Care Plan, 426 F.3d 330, 337 (5th Cir. 2005). In that case, the court said that, because ERISA provides no specific limitations period as to when a suit under ERISA must be filed, we apply state law principles of limitation. Where a plan designates a reasonable, shorter time period, however, that lesser limitations schedule governs.

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