Langlois v. Metropolitan Life Insurance
833 F. Supp. 2d 1182
N.D. Cal.2011Background
- Plaintiff Langlois was employed by MetLife and participated in the MetLife Options and Choices Plan.
- Plaintiff sought LTD benefits after long-term depression and anxiety rendered him unable to work in January 2010.
- MetLife denied LTD benefits on September 29, 2010.
- Plaintiff appealed March 4, 2011; MetLife acknowledged the appeal on March 18, 2011.
- Defendant failed to issue a decision on the appeal within the plan/regulatory timelines (about 287 days); the court later determined de novo review was appropriate.
- The court identifies discretionary authority in the plan administrator and addresses procedural irregularities affecting standard of review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Discretionary authority of plan administrator | Langlois argues SPD shows discretion is vested. | MetLife contends SPD shows discretion as Plan terms. | SPD grants discretionary authority to administrator. |
| Effect of procedural irregularities on standard of review | Failure to decide within deadlines warrants de novo review. | Delay does not negate discretion unless it deems denial. | De novo review applies due to failure to resolve appeal timely. |
Key Cases Cited
- Firestone Tire & Rubber Co. v. Bruch, 489 F.2d 101 (U.S. 1989) (establishes de novo review unless discretionary authority exists)
- Abatie v. Alta Health & Life Ins. Co., 458 F.3d 955 (9th Cir. 2006) (discretionary authority governs standard of review; forfeiture when not exercised)
- Bergt v. Ret. Plan for Pilots Employed by MarkAir, Inc., 293 F.3d 1139 (9th Cir. 2002) (discretionary language supports deference)
- Grosz-Salomon v. Paul Revere Life Ins. Co., 237 F.3d 1154 (9th Cir. 2001) (recognizes discretionary interpretation of plan terms)
- Jebian v. Hewlett-Packard Co. Empl. Benefits Org. Income Prot. Plan, 349 F.3d 1098 (9th Cir. 2003) (whether failure to decide timely amounts to de novo review)
- Gatti v. Reliance Std. Life Ins. Co., 415 F.3d 978 (9th Cir. 2005) (timeliness issues do not automatically shift standard of review)
- Amara v. CIGNA Corp., 131 S. Ct. 1866 (2011) (SPD terms not enforceable if conflict with governing plan terms; but may indicate discretion when aligned with plan)