ERISA-First Circuit Rules That Plaintiff's Claim For Reinstatement of Disability Benefits Is Time-Barred
In Santaliz- Ros v. Metropolitan Life Insurance Company, No. 11-1279 (1st Cir. 2012), the district court found that the plaintiff's claim, which was for reinstatement of disability benefits, was time- barred. It dismissed his claim, and the plaintiff appealed.
In this case, the plaintiff, Luis Arturo Santaliz-Ros ("Santaliz- Ros"), was a participant in his employer-sponsored welfare benefit plan (the "Plan"). Metropolitan Life Insurance Company ("MetLife") insured the Plan and served as claims administrator, adjudicating claims of disability and paying benefits. On September 17, 2001, Santaliz- Ros left his job because of a mental disability. The Plan's insurance policy with MetLife covered mental or nervous disorders or diseases. It provided that disability benefits for those conditions are limited to twenty-four months, unless the disability results from, inter alia, bipolar disorder. Santaliz- Ros became eligible for monthly disability benefits from the Plan on December 16, 2001. He received the benefits until December 16, 2003, when the twenty-four-month payment period expired.
At the expiration time, Santaliz- Ros requested reconsideration of the decision to cease paying disability benefits, arguing that he suffered from bipolar disorder and thus the twenty-four-month cap on payments should not apply to him. MetLife denied his request for reconsideration on February 27, 2004. Santaliz- Ros filed a claim against Metlife in state court in 2004, but he subsequently withdrew that claim, and the claim was dismissed by that court with prejudice on June 20, 2005. On May 28, 2010, Santaliz- Ros filed this case for the reinstatement of his disability benefits in district court in Puerto Rico, under section 502(a)(1)(B) of ERISA (the section allowing participants to sue for benefits) . The question for the First Circuit Court of Appeals (the "Court"): is Santaliz-Ros's claim time barred?
In analyzing the case, the Court noted that Congress has not established a limitations period for ERISA claims brought under section 502(a)(1)(B) of ERISA. Therefore, in adjudicating ERISA claims under that section, federal courts borrow the most closely analogous statute of limitations in the forum state. In Puerto Rico, the default limitations period applicable to contract claims is fifteen years. However, where the contract at issue itself provides a shorter limitations period, that period will govern as long as it is reasonable. In this case, the Plan's policy had a 3-year period of limitation for bringing claims against MetLife. The Court found that this 3-year period is reasonable. This period started no later than by June 20, 2005, when the case he filed in state court in 2004 was dismissed without prejudice . Santaliz- Ros did not file this case in the district court until 2010. Since Santaliz- Ros did not file his claim within the required 3-year period , the Court concluded that his claim is time-barred, and it affirmed the district court's dismissal of the claim.