Edwards v. Briggs & Stratton Retirement Plan
639 F.3d 355
| 7th Cir. | 2011Background
- Edwards, a Briggs & Stratton employee, is a participant in the Briggs & Stratton Retirement Plan under ERISA seeking disability retirement benefits.
- Plan denied Edwards's disability claim on September 26, 2007 based on its own consultant Fritz's evaluation that she was not totally and permanently disabled.
- Denial letter informed Edwards of an 180-day window to appeal the denial to the Plan's Retirement Committee.
- Edwards requested records October 9, 2007 and later engaged counsel to pursue an administrative appeal; the Plan sent deadlines and the Plan document was provided.
- Edwards's appeal, supported by a vocational report, was received by the Plan on April 11, 2008, eleven days after the March 31, 2008 deadline and fifteen days after the March 27, 2008 actual deadline.
- The Plan refused to consider the untimely appeal; Edwards filed suit under ERISA on June 9, 2008; the district court granted summary judgment for the Plan and Edwards appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether untimely appeal excuses exhaustion | Edwards argues substantial compliance should excuse lateness. | Plan argues strict adherence to the 180-day deadline is required. | Untimeliness not excused; exhaustion applied. |
| Whether Wisconsin notice-prejudice rule applies to ERISA appeals | Rule should require prejudice evaluation for delay. | Rule not applicable to ERISA appeals; plan allowed to enforce deadlines. | Not applied to ERISA administrative appeals. |
| Whether October 2007 and February 2008 letters counted as appeals | Letters could reasonably be construed as notices of appeal. | Letters did not constitute appeals or trigger a duty to inquire. | Letters did not constitute appeals. |
| Impact of the plan's conflict of interest on review | Conflict of interest warrants less deference or different review. | Conflict acknowledged but not grave; deference remains under arbitrary and capricious standard. | Conflict not sufficiently grave to alter standard. |
| What is the appropriate standard of review for denial of benefits given discretion | De novo review should apply if no discretionary authority or conflict justifies deference. | Arbitrary and capricious standard applies where plan administrator has discretion. | Arbitrary and capricious standard applies with deference. |
Key Cases Cited
- Metropolitan Life Ins. Co. v. Glenn, 554 U.S. 105 (U.S. 2008) (conflict of interest should be weighed but not de novo review)
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (U.S. 1989) (arbitrary and capricious review when discretion granted)
- Kross v. Western Elec. Co., 701 F.2d 1238 (7th Cir. 1983) (statutory exhaustion and plan claim procedures)
- Powell v. AT&T Commc'ns, Inc., 938 F.2d 823 (7th Cir. 1991) (ERISA exhaustion and procedural requirements)
- Gallegos v. Mount Sinai Med. Ctr., 210 F.3d 803 (7th Cir. 2000) (timeliness and exhaustion principles in ERISA)
- Hess v. Reg-Ellen Mfg. Tool Corp. Employee Stock Ownership Plan, 502 F.3d 725 (7th Cir. 2007) (deferential review when substantial compliance doctrine applied)
- Majeski v. Metropolitan Life Ins. Co., 590 F.3d 478 (7th Cir. 2009) (gravity of conflict inferred from circumstances)
- Marrs v. Motorola, Inc., 577 F.3d 783 (7th Cir. 2009) (conflict of interest assessed by circumstances and safeguards)