Riley v. Metropolitan Life Insurance
744 F.3d 241
| 1st Cir. | 2014Background
- Riley, an MetLife employee, began suffering pain in 2000, leading to STD and later LTD claims; the LTD plan paid benefits based on Riley's 2002 non-managerial salary, resulting in a low monthly award.
- Riley argued in 2004-2005 that his LTD should be calculated using his 2000 managerial salary; MetLife disagreed and issued a $50 monthly benefit in 2005.
- Riley refused to cash LTD checks and sought counsel; a 2007 state court claim for misdeeds under Mass. Gen. Laws ch. 93A was dismissed as preempted by ERISA and later affirmed on appeal.
- A 2011, improperly served federal suit was dismissed; Riley, with new counsel, filed the ERISA claim for unpaid benefits in 2012.
- District court granted summary judgment to MetLife, holding Riley’s ERISA claim was time-barred by a six-year statute of limitations, based on accrual from the initial miscalculation.
- Court held that accrual occurs when a plan repudiates a claim for a specific amount, not per each subsequent underpayment, rejecting an installment-contract theory.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When does ERISA accrual begin for underpayments? | Riley: accrues with each underpayment as installments. | MetLife: accrual occurs at the initial miscalculation/denial, not per payment. | Accrual begins at first repudiation; not per-payment. |
| Does the Plan's overpayment recovery clause create a symmetric right to recover underpayments? | Riley: symmetry allows recovery of underpayments. | MetLife: express terms govern; no reciprocal right implied. | No symmetry; plan terms control; no underpayment recovery right. |
| May equitable arguments modify plan terms to create additional remedies? | Riley: equitable reading could add underpayment recovery. | MetLife: ERISA plan documents limit rights to expressed terms. | Equitable arguments cannot alter written plan terms. |
| Is Riley's claim timely under Massachusetts six-year limitations, given accrual ruling? | Riley: some payments within six years remain recoverable. | MetLife: accrual barred by initial repudiation; later payments fall outside six years. | Claim untimely; accrual rule bars recovery. |
Key Cases Cited
- Miller v. Fortis Benefits Ins. Co., 475 F.3d 516 (3d Cir. 2007) (ERISA accrual after repudiation; no per-payment accrual)
- Novella v. Westchester Cnty., 661 F.3d 128 (2d Cir. 2011) (accrual in single decision with lasting effects)
- Pisciotta v. Teledyne Indus., Inc., 91 F.3d 1326 (9th Cir. 1996) (knowledge-based accrual under ERISA provisions)
- US Airways, Inc. v. McCutchen, 133 S. Ct. 1537 (S. Ct. 2013) (Plan terms control; expressio unius est exclusio alterius)
- Conkright v. Frommert, 559 U.S. 506 (2010) (ERISA plan's actuarial soundness and deference to plan determinations)
- Santaliz-Ríos v. Metro. Life Ins. Co., 693 F.3d 57 (1st Cir. 2012) (borrowed statute-of-limitations and accrual principles for ERISA)