Santaliz-Rios v. Metropolitan Life Insurance Co
693 F.3d 57
| 1st Cir. | 2012Background
- ERISA claim for reinstatement of disability benefits was asserted; district court ruled time-barred and dismissed.
- Plan/MetLife policy imposes a three-year limitations period on legal actions.
- Disability began Sept 17, 2001 with eligible long-term disability on Dec 16, 2001 and benefits paid through Dec 16, 2003.
- MetLife denied reconsideration on Feb 27, 2004; appellant sought information but claims were not timely acted upon.
- Appellant filed a Puerto Rico state court complaint Dec 15, 2004, withdrew June 15, 2005; federal ERISA action filed May 28, 2010.
- District court and court of appeals upheld the three-year contract-based limitations period and declined tolling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether contractually imposed three-year period governs | Santaliz-Ríos argues tolling or unfairness should extend time. | MetLife contends three-year period is reasonable and applicable. | Three-year period applies; tolling rejected. |
| Whether tolling or other equitable grounds save the claim | Puerto Rico filing tolled the period; bipolar diagnosis argued to warrant delay. | Tolling not supported; complaint withdrew and period restarted; diagnosis not a basis for tolling. | Tolling rejected; period elapsed before 2010 filing. |
Key Cases Cited
- Island View Residential Treatment Ctr. v. Blue Cross Blue Shield of Mass., Inc., 548 F.3d 24 (1st Cir. 2008) (borrowing state limitations period when contract does not designate one)
- Edes v. Verizon Commc'n, Inc., 417 F.3d 133 (1st Cir. 2005) (choice of borrowing statute framework for ERISA claims)
- Nazario Martinez v. Johnson & Johnson Baby Prods., Inc., 184 F. Supp. 2d 157 (D.P.R. 2002) (application of Civil Code fifteen-year period to ERISA where no contract period exists)
- Rios-Coriano v. Hartford Life & Accident Ins. Co., 642 F. Supp. 2d 80 (D.P.R. 2009) (reasonableness of contractually established limitations period)
- Rodríguez v. Suzuki Motor Corp., 570 F.3d 402 (1st Cir. 2009) (regarding tolling and limitations in ERISA context)
- River St. Donuts, LLC v. Napolitano, 558 F.3d 111 (1st Cir. 2009) (considerations about raising new arguments on appeal)