997 F. Supp. 2d 85
D. Mass.2014Background
- Plaintiff Sharon Prouty sued C & S Wholesale Grocers (plan administrator/employer) and Hartford Life (insurer) under ERISA after her husband, a former employee, lost group life coverage post‑termination and later died.
- The plan’s summary plan description (SPD) described termination and a conversion privilege (must apply in 31 days), but plaintiff alleges neither defendant informed her husband of the conversion right and that he did not timely convert.
- Hartford Life denied Plaintiff’s claim and administrative appeal; Plaintiff then filed this suit seeking equitable relief under 29 U.S.C. § 1132(a)(3) for alleged fiduciary breaches in notice/SPD content.
- Defendants moved to dismiss under Rule 12(b)(6); defendants submitted SPDs (one dated Dec 2005, one Mar 2006); court allowed consideration of the SPD as authentic and central to the claim.
- Court found Hartford Life had no statutory duty to furnish the SPD (plan administrator’s duty), the SPD complied with ERISA § 102, and ERISA does not require post‑termination notice of life‑insurance conversion rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May court consider the SPD on a 12(b)(6) motion? | The SPD copies are not properly authenticated and have inconsistent dates. | SPD is authenticated by insurer’s appeal specialist and is central/sufficiently referenced. | Court considered the SPD as authentic, central, and properly referenced. |
| Did Hartford Life owe a statutory duty to provide or ensure an understandable SPD? | Hartford Life interpreted plan terms and thus had a duty to provide understandable information. | ERISA places SPD duties on the plan administrator, not the insurer. | Hartford Life had no duty to furnish or ensure the SPD’s content under ERISA. |
| Did the SPD violate ERISA § 102 by failing to adequately notify of conversion rights? | The SPD buried conversion info and did not make clear that "conversion" meant individual coverage. | SPD contains clear conversion language; ERISA does not require notice of life‑insurance conversion rights. | SPD met statutory requirements; no ERISA violation for failure to give extra conversion notice. |
| Is equitable relief available under § 502(a)(3) to convert the terminated group policy or otherwise remedy alleged notice defects? | Plaintiff seeks equitable relief (reformation/ordering conversion) under Amara to remedy misleading or inadequate plan communications. | Plaintiff is not a beneficiary under any plan term and alleges no change in plan terms or unjust enrichment that would justify equitable relief. | Court held no equitable grounds stated; § 502(a)(3) relief not available on these facts and dismissed the complaint. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: plausibility required to survive 12(b)(6))
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state plausible claim, not speculative)
- CIGNA Corp. v. Amara, 563 U.S. 421 (2011) (equitable reformation and remedies available for misleading plan communications in some circumstances)
- Todisco v. Verizon Commc’ns, Inc., 497 F.3d 95 (1st Cir. 2007) (limits on suits seeking benefits not authorized by plan terms)
- Howard v. Gleason Corp., 901 F.2d 1154 (2d Cir. 1990) (ERISA does not mandate notice of life‑insurance conversion privileges)
- Lee v. Burkhart, 991 F.2d 1004 (2d Cir. 1993) (ERISA SPD/plan information duties imposed on plan administrator rather than every fiduciary)
- Curtiss‑Wright Corp. v. Schoonejongen, 514 U.S. 73 (1995) (ERISA’s scheme relies on written plan documents to inform beneficiaries of rights)