Silva v. Metropolitan Life Insurance
762 F.3d 711
| 8th Cir. | 2014Background
- Abel Silva died June 27, 2010; Silva sought life insurance benefits for Abel under Savvis’s ERISA plan; MetLife denied asserting Abel did not have an approved policy due to lack of evidence of insurability; Abel enrolled late and premium deductions occurred; Plan required evidence of insurability but the Plan did not define the term or provide clear enrollment steps; MetLife and Sawis discovered about 200 other employees lacking required statements; Silva sued in district court under ERISA §1132(a)(1)(B) and later sought to amend to add §1132(a)(3) equitable relief; district court granted summary judgment on §1132(a)(1)(B) and denied amendment; on appeal, the Eighth Circuit reverses in part and remands.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of evidence of insurability under the Plan | Silva argues the Plan never defined the term and MetLife overreached. | MetLife contends evidence of insurability (including Statement of Health) is required for late or high-amount enrollments. | Material facts unresolved; remand for proper interpretation of the Plan. |
| Whether Amara allows equitable relief under §1132(a)(3) for this case | Amara permits surcharge, reformation, and estoppel as equitable relief for fiduciary breaches. | Pichoff and Varity limit §1132(a)(3) relief to non-compensatory forms. | Amara changed the legal landscape; §1132(a)(3) relief may be available. |
| Whether Silva may plead §1132(a)(3) alongside §1132(a)(1)(B) | Plaintiff may plead alternative theories without duplicative recovery. | Pilger/Varity suggest potential duplication; may require election. | Plaintiff may plead both; not barred at pleading stage; not duplicative at remand stage. |
| Remedies available under §1132(a)(3) for fiduciary breaches | Equitable relief could include make-whole damages for full policy benefits. | Relief limited to traditional equitable remedies unless Amara permits more. | Equitable relief may include make-whole damages under Amara; remand to determine appropriate remedy. |
Key Cases Cited
- Amara v. CIGNA Corp., 131 S. Ct. 1866 (2011) (recognizes equitable relief (surcharge, reformation, estoppel) under §1132(a)(3))
- Pichoff v. QHG of Springdale, Inc., 556 F.3d 728 (8th Cir. 2009) (limits ‘other appropriate equitable relief’ to traditional equitable remedies (pre-Amara))
- Pilger v. Sweeney, 725 F.3d 922 (8th Cir. 2013) (discusses Varity/Pilger interplay of §1132(a)(1)(B) and §1132(a)(3))
- Varity Corp. v. Howe, 516 U.S. 489 (1996) (structural guidance on catchall §1132(a)(3) scope and safety net role)
- Gearlds v. Entergy Servs., Inc., 709 F.3d 448 (5th Cir. 2013) (treats Amara remedies as applicable to fiduciary breaches under §1132(a)(3))