Metropolitan Life Insurance Co. v. Waddell
194 F. Supp. 3d 1340
N.D. Ga.2016Background
- Decedent Lanier G. Waddell held two employer-sponsored MetLife group policies (Basic and Term), each $60,000; Basic named his wife Ann as beneficiary on file, Term had no beneficiary on file at death.
- Lanier died December 23, 2013. Forms purporting to change beneficiary to his son Devin, dated December 12, 2013, were submitted to MetLife post-death on April 29, 2014 by Devin’s counsel.
- MetLife denied paying Devin: no change form was on file, and the policies required the insured to file/return the form for the change to be effective. MetLife later attempted to pay Ann but was enjoined by litigation; MetLife interpleaded funds.
- Devin argued the dated forms were effective as of the signing date (even if received postmortem) and sought summary judgment; Ann (and her conservator) moved for summary judgment affirming MetLife’s decision to deny Devin and pay Ann.
- Court found both policies governed by ERISA, plan documents conferred discretionary authority on the administrator, MetLife conducted an ERISA administrative process, and MetLife’s denial was supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument (Devin) | Defendant's Argument (Ann/MetLife) | Held |
|---|---|---|---|
| Standard of review for MetLife’s denial | Procedural defects justify de novo review | Plan grants administrator discretionary authority → deferential review (arbitrary and capricious) | ERISA multi-step review applies; administrator had discretionary authority; deferential review appropriate |
| Are the December 12, 2013 beneficiary forms effective though received after death? | Forms signed by decedent; policy language says change effective as of signing even if insurer receives after death → so Devin is beneficiary | No form was filed/returned to insurer by the covered person before death; policy requires the participant to file/return the form; submission post-death by third party is insufficient | Forms were not on file and were not shown to have been returned by decedent; MetLife reasonably denied Devin’s claim |
| Did decedent substantially comply with change-of-beneficiary requirements? | Substantial compliance doctrine applies; decedent intended change and took steps (filled forms, attempted to fax) | No evidence decedent sent or arranged sending; no proof he did all he reasonably could; intent unclear (will/trust suggested different beneficiary plan) | No substantial compliance: evidence insufficient that decedent effected or intended final filing |
| Is the policy ambiguous (construed against insurer) or did MetLife act unreasonably? | Any ambiguity should be construed contra proferentem; MetLife’s discretion was impermissible | Policy language and line-of-succession are clear; administrator’s interpretation reasonable | Court finds provisions unambiguous for purposes here and MetLife’s interpretation reasonable; no contra proferentem relief |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (genuine issue of material fact standard)
- Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (ERISA review standard—de novo unless plan grants discretion)
- Buce v. Allianz Life Ins. Co., 247 F.3d 1133 (11th Cir.) (SPD discretionary language can confer administrator discretion)
- Tippitt v. Reliance Standard Life Ins. Co., 457 F.3d 1227 (11th Cir.) (satisfactory-proof provisions confer discretion)
- Lee v. Blue Cross/Blue Shield of Ala., 10 F.3d 1547 (11th Cir.) (review confined to facts known to administrator at decision time)
- Phoenix Mut. Life Ins. Co. v. Adams, 30 F.3d 554 (4th Cir.) (substantial compliance doctrine for beneficiary changes)
- First Capital Life Ins. Co. v. AAA Commc’ns, Inc., 906 F. Supp. 1546 (N.D. Ga.) (substantial compliance where insured did all it could and failure was ministerial agent error)