Metropolitan Life Insurance Company v. Devin Lanier Waddell
697 F. App'x 989
| 11th Cir. | 2017Background
- Lanier Waddell participated in two MetLife-funded Alcatel retirement life-insurance plans (Basic and Term), each $60,000; wife Ann was beneficiary of Basic (1983); no beneficiary on file for Term at his death in December 2013.
- Ann Waddell had been incapacitated since 2003 and was represented by conservator Anne Marie Bishop; Devin Waddell is Lanier’s son and estate administrator and sought the proceeds.
- After Lanier’s death, MetLife determined Ann (through her conservator) was the proper beneficiary under both plans and declined Devin’s claim; Devin later submitted purported December 12, 2013 change-of-beneficiary forms naming himself, which MetLife received post-mortem.
- MetLife denied those forms as invalid because they were not on file before Lanier’s death and were submitted by others after death; MetLife attempted to pay Ann’s conservator but was enjoined temporarily while Georgia litigation proceeded, then interpleaded the funds into federal court.
- District court granted summary judgment to Ann and Bishop, applying deferential ERISA review (administrator discretion) and finding MetLife’s denial was reasonable based on the administrative record; it also rejected substantial-compliance and ambiguity arguments even under de novo review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ERISA governs the Plans and what standard of review applies | Waddell (Devin) argued for de novo review / review of outside evidence | MetLife and beneficiaries argued Plans are ERISA plans and grant administrator discretion, requiring deferential review | Court: Plans are ERISA-governed; administrator had discretion; apply deferential framework (affirmed) |
| Whether December 12, 2013 forms constituted an effective beneficiary change | Devin: forms were signed by Lanier pre-death and effective upon receipt per plan/SPD language | MetLife: forms were not on file pre-death and were submitted post-mortem by others; plan requires insured to return/file forms himself (or arrange) | Court: MetLife reasonably found no evidence Lanier returned or intended to return forms; denial upheld |
| Whether substantial compliance/federal common law can validate the post-death forms | Devin: equitable substantial-compliance should validate forms given intent and actions short of filing | Ann/MetLife: Kennedy and plan language foreclose reliance on external evidence; substantial-compliance not satisfied here | Court: Even assuming doctrine applies, Lanier did not substantially comply (no clear intent + no positive action to effectuate) |
| Whether plan language is ambiguous or grants impermissible discretion to insurer | Devin: language ambiguous; should construe against MetLife | MetLife/Ann: language clear; discretion properly conferred to plan administrator | Court: language not ambiguous; discretion lawful; construction in favor of beneficiary (Ann) affirmed |
Key Cases Cited
- Blankenship v. Metro. Life Ins. Co., 644 F.3d 1350 (11th Cir.) (multi-step framework for ERISA benefits-review and limits review to materials before administrator)
- Kennedy v. Plan Admin. for DuPont Sav. & Inv. Plan, 555 U.S. 285 (2009) (ERISA precludes courts from relying on external evidence of intent when plan provides clear designation procedures)
- Phoenix Mut. Life Ins. Co. v. Adams, 30 F.3d 554 (4th Cir.) (formulation of federal common-law substantial-compliance doctrine: intent plus positive action)
- Capone v. Aetna Life Ins. Co., 592 F.3d 1189 (11th Cir.) (standard of review for district court’s grant of summary judgment reviewed de novo)