Brown v. Rawlings Financial Services, LLC
2017 U.S. App. LEXIS 15934
| 2d Cir. | 2017Background
- Jennifer Brown, a participant in an ERISA-governed health plan, requested plan documents from the plan administrator and its contractors between Dec. 2012 and July 2014; full compliance occurred in Jan–Feb 2015.
- Brown sued under ERISA § 502(c)(1) seeking statutory damages for the administrator’s failure to furnish requested information within 30 days.
- The district court dismissed the complaint as time-barred, applying Connecticut’s one-year statute of limitations for actions to recover civil forfeitures (Conn. Gen. Stat. § 52-585).
- Brown appealed, arguing alternative Connecticut limitations periods should apply: the six-year contract limitation or the three-year CUTPA/CUIPA limitation.
- The Second Circuit considered which state statute of limitations is the “most analogous” to an ERISA § 502(c)(1) claim and whether § 502(c)(1) damages are punitive (penal) or remedial.
- The court held § 502(c)(1) statutory damages are punitive in nature and therefore most analogous to Connecticut’s civil-forfeiture (penal) statute; Brown’s claim accrued in Aug. 2014 and was filed Oct. 2015, so it was time-barred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicable state statute of limitations for ERISA § 502(c)(1) claim | Brown: use 6-year contract or 3-year CUTPA/CUIPA limitations | Defs: use Connecticut’s 1-year civil-forfeiture (penal) limitation | Court: 1-year civil-forfeiture statute is most analogous |
| Nature of § 502(c)(1) damages (punitive vs. remedial) | Brown: damages are remedial/compensatory | Defs: damages are punitive/penal | Court: § 502(c)(1) damages are punitive (penal) in nature |
| Accrual date of Brown’s claim | Brown: accrual later or tolled such that claim is timely | Defs: accrual when 30-day statutory response period expired (Aug. 2014) | Court: claim accrued Aug. 2014 (30 days after last request) |
| Timeliness of suit | Brown: filed within applicable limitations (if longer period applied) | Defs: filed after one-year penal limitations expired | Court: complaint filed Oct. 2015 is time-barred under 1-year limit; dismissal affirmed |
Key Cases Cited
- Burke v. PriceWaterhouseCoopers LLP Long Term Disability Plan, 572 F.3d 76 (2d Cir. 2009) (state limitations period: use most nearly analogous statute)
- Miles v. N.Y. State Teamsters Conference Pension & Ret. Fund, 698 F.2d 593 (2d Cir. 1983) (same instruction on borrowing state limitations)
- Groves v. Modified Ret. Plan for Hourly Paid Employees of Johns Manville Corp. & Subsidiaries, 803 F.2d 109 (3d Cir. 1986) (describing § 502(c)(1) penalties as designed to induce administrator compliance)
- Mondry v. Am. Family Mut. Ins. Co., 557 F.3d 781 (7th Cir. 2009) (characterizing § 502(c)(1) as penal rather than compensatory)
- Stone v. Travelers Corp., 58 F.3d 434 (9th Cir. 1995) (contrasting view that § 502(c)(1) is not penal)