Todd Babin v. Quality Energy Services, Inc.
877 F.3d 621
| 5th Cir. | 2017Background
- Todd Babin, a Louisiana resident and former employee of Quality Energy, applied for short-term disability in 2012; the insurer denied the claim in Feb. 2013 for a missing form Babin alleges Quality Energy failed to complete.
- On Feb. 5, 2014 Babin’s counsel requested short- and long-term disability plan documents from Quality Energy; Babin alleges he received none (or received them only after suit was filed).
- Babin filed suit under ERISA in Oct. 2015 alleging failure to pay benefits (later settled) and a § 1132(c) claim for failure to produce plan documents.
- Quality Energy moved for summary judgment on the § 1132(c) claim as time-barred; the district court applied Louisiana’s one-year prescriptive period for delictual claims and granted summary judgment.
- On appeal, Babin argued the ten-year contractual prescriptive period should apply or that the limitations period should be tolled while a benefits claim was pending.
- The Fifth Circuit held a § 1132(c) claim is analogous to a delictual (tort-like) state claim under Louisiana law, not a contract claim, and declined to consider Babin’s untimely tolling argument; it affirmed summary judgment as time-barred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which Louisiana prescriptive period governs an ERISA § 1132(c) claim? | Babin: ten-year contractual period applies because obligation arose from plan/fiduciary duties. | Quality Energy: one-year delictual period applies because § 1132(c) imposes a general statutory duty and penalties, not contractual remedies. | One-year delictual prescriptive period applies. |
| Whether § 1132(c) is analogous to breach of fiduciary duty (affecting limitations) | Babin: § 1132(c) flows from fiduciary/contractual obligations, so longer period applies. | Quality Energy: § 1132(c) imposes statutory penalties separate from plan terms; not a contract/fiduciary claim for prescriptive-period purposes. | § 1132(c) resembles a delictual statutory claim and does not require intentional misconduct; one-year period applies. |
| Whether plaintiff alleged intentional misconduct (affecting classification) | Babin: refusal to produce cannot be mere negligence; alleged facts would show malice if developed. | Quality Energy: complaint contains no plausible allegations of malice or intent; § 1132(c) claims do not require intent. | No adequate allegations of deliberate misconduct; treated as delictual (tort-like) claim. |
| Whether tolling applies while benefits claim is pending | Babin: limitations tolled during pendency of benefits claim. | Quality Energy: argument not raised below; no tolling. | Appellate court declined to consider tolling (issue forfeited); claim accrued after the 30-day statutory response period and was time-barred. |
Key Cases Cited
- Vela v. City of Houston, 276 F.3d 659 (5th Cir. 2001) (summary judgment standard and de novo appellate review)
- Lopez ex rel. Gutierrez v. Premium Auto Acceptance Corp., 389 F.3d 504 (5th Cir. 2004) (ERISA § 1132(c) claims are analogous to non-contractual disclosure/penalty claims; borrow closest state limitation)
- DelCostello v. Int’l Bhd. of Teamsters, 462 U.S. 151 (1983) (federal courts borrow most analogous state statute of limitations for federal claims)
- Brown v. Rawlings Fin. Servs., LLC, 868 F.3d 126 (2d Cir. 2017) (§ 1132(c) claim accrues after administrator’s 30-day response period expires)
- LaRue v. DeWolff, Boberg & Assocs., Inc., 552 U.S. 248 (2008) (distinguishing fiduciary breach remedies that affect plan assets from individual injuries)