Andre Lesgras v. Aetna Life Insurance, 786 F.3d 1233

LeGras sustained a serious back injury while employed at FedEx and began LTD benefits in May 2009.
AETNA administers FedEx's LTD Plan benefits and issued an April 18, 2011 denial letter denying total disability benefits.
The denial advised that LeGras could appeal within 180 days of receipt.
The 180-day period expired on Saturday October 15, 2011; LeGras mailed his appeal on Monday October 17, 2011.
AETNA denied the appeal as untimely and the district court dismissed the suit for failure to exhaust administrative remedies.
The majority adopts a federal common-law mailbox rule for ERISA time computation; the dissent objects to rewriting contract terms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 180-day appeal period excludes weekends.	LeGras: deadline extends to next business day.	AETNA: contract terms set the 180 days; no extension rule.	Yes; period extends to next business day; timely.
Whether ERISA federal common law permits rewriting private plan terms to apply Rule 6(a) timing.	LeGras argues Rule 6(a) applies to compute time.	AETNA argues plan terms govern; no common-law rewrite.	Yes; ERISA common law allows time-computation extension for weekends/holidays.

Street v. United States, 133 U.S. 299 (1890) (deadline on weekend may be extended to next day)
Armstrong v. Tisch, 835 F.2d 1139 (5th Cir. 1988) (next-business-day extension adopted in some contexts)
Jones v. Georgia-Pacific Corp., 90 F.3d 114 (5th Cir. 1996) (private contract with unambiguous terms not rewritten by Rule 6)
Schikore v. BankAmerica Supplemental Ret. Plan, 269 F.3d 956 (9th Cir. 2001) (mailbox rule in ERISA litigation; evidentiary question context)
Saltarelli v. Bob Baker Group Medical Trust, 35 F.3d 382 (9th Cir. 1994) (reasonable expectations doctrine applied to ERISA insurance coverage)
Security Life Ins. Co. of Am. v. Meyling, 146 F.3d 1184 (9th Cir. 1998) (recognizing reeisson remedy; limits on applying common law to plans)