In Babin v. Quality Energy Services, Incorporated, No. 17-30059 (5th Cir. 2017), Todd M. Babin worked for Quality Energy Services, Inc., until he became disabled in 2012. He applied for short-term disability benefits through Quality Energy’s employee benefit plan. His application was denied in February 2013. In February 2014, he requested documents regarding both the short- and long-term disability plans, but he alleges that Quality Energy never sent those documents to him. Babin ultimately filed suit against Quality Energy and its disability insurer in October 2015, alleging claims under ERISA for failure to pay benefits and failure to produce plan documents.
The parties settled the failure-to-pay-benefits claim, and Quality Energy moved for summary judgment on the failure-to-produce-documents claim. The district court concluded that Babin’s claim was time-barred and granted summary judgment. On appeal, Babin argues that Louisiana’s ten-year prescriptive period for personal actions should govern his claim for failure to produce documents under 29 U.S.C. § 1132(c). Upon reviewing the case, the Fifth Circuit Court of Appeals (the “Court”) concluded, however, that Louisiana’s one-year period for delictual actions (that is, generally, breach of duty actions) applies and that Babin’s claim is time-barred. As a result, the Court affirmed the district court’s ruling.