Melinda Webb v. Liberty Life Assurance Company of Boston
692 F. App'x 603
| 11th Cir. | 2017Background
- Ronald Webb, an Adobe employee, died from a gunshot wound on December 27, 2013; the coroner ruled the death a suicide. Melinda Webb was beneficiary of basic and optional life and accidental-death ERISA-covered benefits.
- Adobe notified Liberty Life and submitted a proof-of-death form; Ms. Webb provided requested proof (including the death certificate) on January 24, 2014, within 30 days of the loss. Liberty paid basic life benefits but denied optional life and accidental-death benefits because of the suicide ruling.
- Liberty denied Ms. Webb’s internal appeal and sent a June 23, 2014 letter stating the appeal was exhausted and that “further review will be conducted.” Ms. Webb’s counsel wrote on May 5, 2015; Liberty replied on May 15, 2015, calling the June 23 statement a typo and saying no further review would be conducted.
- Ms. Webb sued on June 12, 2015. The District Court granted Liberty summary judgment, holding the policy’s contractual limitations period (1 year + 30 days) had expired and barred the claim.
- The Eleventh Circuit reviewed de novo, found the policy language unambiguous as to the timing rules for proof and suit, but concluded a factual question existed whether Ms. Webb reasonably relied on Liberty’s statement that “further review will be conducted,” making the limitations period potentially unreasonable. The court vacated and remanded for the district court to decide that factual issue (and to consider the administrative record if necessary).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper interpretation of policy limitations period | Webb: "Proof required" is not absolute until one year + 30 days; limitations = 2 years + 30 days | Liberty: Thirty-day proof deadline applied; suit must be brought within 1 year + 30 days after that | Policy read according to plain language: extra year applies only where proof could not reasonably be furnished within 30 days; Webb filed within 30 days, so 1 year + 30 days applies |
| Ambiguity / contra proferentem | Webb: If ambiguous, interpret against drafter (Liberty) | Liberty: Policy is clear; no ambiguity | Court: Policy not ambiguous; plain meaning supports Liberty’s interpretation |
| Reasonableness of contractual limitations period given Liberty’s conduct | Webb: Limitations unreasonable because she reasonably relied on Liberty’s June 23 statement that further review would be conducted, delaying suit | Liberty: Webb had time after June 23 to sue; she failed to follow up diligently; no conduct prevented suit | Court: Whether Webb reasonably relied is a factual question; if reasonable reliance is shown, the limitations period would be unreasonable; remand for factual determination |
| Scope of appellate review vs. district court findings | Webb: Court should consider administrative record and whether denial was proper | Liberty: Appellate review can resolve denial on the administrative record | Court: Vacated district judgment and remanded; directed district court to decide reliance fact question in the first instance and consider administrative record if needed |
Key Cases Cited
- Byars v. Coca-Cola Co., 517 F.3d 1256 (11th Cir. 2008) (summary judgment standard review de novo)
- Northlake Reg’l Med. Ctr. v. Waffle House Sys. Emp. Benefit Plan, 160 F.3d 1301 (11th Cir. 1998) (factors for assessing reasonableness of ERISA contractual limitations periods)
- Heimeshoff v. Hartford Life & Accident Ins. Co., 134 S. Ct. 604 (2013) (enforcing contractual limitations provisions and importance of time to file suit after internal review)
- Alexandra H. v. Oxford Health Ins. Inc. Freedom Access Plan, 833 F.3d 1299 (11th Cir. 2016) (interpretation of ERISA plan terms under federal common law)
- Williams v. Wright, 927 F.2d 1540 (11th Cir. 1991) (appellate courts should defer factual issues to the district court to decide in the first instance)