ERISA-Eighth Circuit Affirms Summary Judgment Against Plaintiff Since She Failed To Exhaust Her Administrative Remedies

In Reindl v. Hartford Life and Accident Insurance Company, No. 12-1975 (8th Cir. 2013), the plaintiff, Susan Reindl (“Reindl”), had brought this suit under ERISA, claiming that the defendant, Hartford Life and Accident Insurance Company (“Hartford”), had wrongfully terminated her long-term disability (“LTD”) benefits under an employer-sponsored plan (the “Plan”). Hartford was the administrator of the Plan. The district court granted summary judgment in favor of Hartford, concluding Reindl failed to exhaust her administrative remedies because she did not file a timely administrative appeal.

In this case, Reindl had stopped working in April 2005 due to physical impairments. She successfully applied for LTD benefits under the Plan and began receiving those benefits. Hartford later reassessed Reindl’s physical condition, however, and decided she was not totally disabled and could perform sedentary work. As a result, Hartford terminated Reindl’s disability benefits on November 25, 2008. The letter Hartford sent to Reindl informed her she had 180 days to file an administrative appeal, and further informed her an appeal was to be addressed to Hartford’s Claim Appeal Unit in Hartford, Connecticut. Reindl sought the services of a lawyer to challenge the termination of her benefits. On December 12, 2008, Reindl’s lawyer sent a letter to Hartford’s Benefits Management Services in Bloomington, Minnesota, which essentially requested medical records. Hartford forwarded Reindl’s medical records to the lawyer in February 2009. On July 8, 2009, more than 180 days after Reindl’s benefits had been terminated, the lawyer sent a letter to Hartford’s Claim Appeal Unit, which among other things requested a reversal of the decision to terminate the LTD benefits. On August 6, 2009, Hartford sent a letter to the lawyer stating the appeal had not been received within the “180 days from the date you received your claim denial.” and further said the case was closed. This suit ensued.

In analyzing the case, the Eighth Circuit Court of Appeals (the “Court”) noted that a timely administrative appeal is a prerequisite to filing an action under ERISA in federal court challenging the denial of Plan benefits. It further noted that, based on the Plan’s language, Hartford’s decision to deny LTD benefits in the case is entitled to a deferential review. Here, Hartford ultimately denied benefits by concluding Reindl failed to file a timely administrative appeal. As such, the issue becomes whether Hartford’s determination that the December 2008 letter did not constitute an appeal was reasonable. The Court concluded that the determination was reasonable . Hartford’s termination letter instructed Reindl to file an appeal with Hartford’s Claim Appeal Unit in Hartford, Connecticut. The December 2008 letter was sent instead to Hartford’s Benefit Management Services in Bloomington, Minnesota. In addition, Hartford’s termination letter stated any appeal of the termination “should clearly outline your position and any issues or comments you have in connection with your claim and our decision to deny your request for benefits under the Policy,” which the December 2008 letter did not do. Instead, the December 2008 letter merely stated its purpose was “to request a copy of any and all medical records you may have in your file on my client.” Under these circumstances, Hartford reasonably could have construed the December 2008 letter to be merely a request for documents Reindl’s lawyer sought to review before determining whether to file an appeal in the future, not an administrative appeal itself. As such, the Court affirmed the district court’s summary judgment for Hartford.

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