Grant v. Eaton Corporation Long-Term Disability Plan
3:10-cv-00164
S.D. Miss.Feb 6, 2013Background
- Grant sues Eaton LTD Plan for benefits after denial; plan administrator and sponsor is Eaton Corporation.
- Plaintiff applied for Social Security Disability with onset date August 12, 2003 and SSA found disability effective that date.
- Sedgwick denied LTD benefits on June 12, 2008; action filed after reconsideration denial in 2010.
- Court remanded in 2011 for full and fair review to address whether one-year filing deadline was waived.
- Committee on remand in 2012 upheld denial, finding no waiver of the one-year deadline.
- Plaintiff moved to amend to add §1132(c)(1) penalties against Eaton for alleged failure to provide documents under §1024(b)(4); motion granted in 2013.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether amendment stating §1132(c) penalties is viable | Grant argues penalties under §1132(c) apply | Eaton argues futility; no viable §1132(c) claim | Amendment granted; viable claim asserted |
| Whether documents requested fall under §1024(b)(4) disclosure | Requests for Admin. Services Agreement and claims manual | Documents not plan documents under §1024(b)(4) | Some documents may fall outside §1024(b)(4) while Administrative Services Agreement may, under some circumstances, be subject to disclosure |
| Whether Admin. Services Agreement can be disclosed under ERISA | ASA may be within §1024(b)(4) or §1133 disclosures | ASA generally not plan documents; may be excluded | Court notes possible §1024(b)(4) coverage; cannot conclude as matter of law |
| Whether requests were properly directed to Plan Administrator | Requests were properly directed to plan administrator | Requests to counsel were improper | Plaintiff’s allegation accepted for purposes of motion; proper direction-to-administrator not conclusively denied |
| Whether amendment would cause delay or prejudice | Amendment necessary for proper remedy | Amendment would cause delay | Amendment granted; no undue prejudice shown |
Key Cases Cited
- Brown v. J.B. Hunt Transport Servs., Inc., 586 F.3d 1079 (8th Cir. 2009) (claims manuals not within § 1024(b)(4))
- Fisher v. Metropolitan Life Ins. Co., 895 F.2d 1073 (5th Cir. 1990) (plan could incorporate administrative services)
- Shaver v. Operating Eng'rs Local 428 Pension Trust Fund, 332 F.3d 1198 (9th Cir. 2003) (documents that govern plan operation may fall under disclosure)
- Mondry v. American Family Mut. Ins. Co., 557 F.3d 781 (7th Cir. 2009) (documents relevant to claim may be disclosed under §1133)
- Wilczynski v. Lumbermens Mut. Cas. Co., 93 F.3d 397 (7th Cir. 1996) (§1132(c) penalties not for §1133 violations alone)
- Heffner v. Blue Cross and Blue Shield of Alabama, Inc., 443 F.3d 1330 (11th Cir. 2006) (contracts may control plan operation and be subject to disclosure)
- Cassidy v. Campbell Soup Co., 898 F. Supp. 1118 (D.N.J. 1995) (administrative services agreements may be disclosure-worthy where they govern plan operation)