Williams v. Hartford Life and Accident Insurance Company
3:17-cv-00927
| S.D. Miss. | Apr 19, 2018Background
- Plaintiff Alexander Williams, a Flowers Foods employee, received group long-term disability (LTD) coverage through Hartford Life & Accident Insurance Co.; he stopped working on December 14, 2011 due to illness.
- Williams received short-term disability benefits through December 23, 2012, which Hartford treated as the end of the policy’s elimination period.
- The LTD claim was terminated November 10, 2014; Hartford denied Williams’s appeal on May 12, 2015.
- Williams sued for LTD benefits on October 20, 2017 (filed in state court, removed to federal court); state-law claims were dismissed as preempted by ERISA and he filed an amended complaint.
- The LTD policy contained a three-year limitations period for suit, which begins when proof of loss is due (proof due within 90 days after completion of the elimination period).
- Hartford moved to dismiss under Rule 12(b)(6), arguing Williams’s suit was time-barred; the court granted the motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams’s ERISA claim is time-barred under the policy’s limitations period | Williams argued the proof-of-loss deadline was extended to December 24, 2014 because Hartford requested additional documentation | Hartford argued the 90-day proof-of-loss deadline ran from Dec. 23, 2012 (deadline Mar. 24, 2013) so the 3-year limitations expired Mar. 24, 2016, before the Oct. 2017 suit | Court held claim time-barred: limitations began Mar. 24, 2013 and expired Mar. 24, 2016; suit filed too late |
| Whether the court should consider extrinsic affidavit evidence on the 12(b)(6) motion | Williams proffered an affidavit excerpt to show Hartford extended the deadline | Hartford opposed consideration; court noted discretion under Rule 12(b)(6)/12(d) when outside materials are presented | Court declined to rely on extrinsic evidence because policy terms governed; did not convert motion to summary judgment and dismissed as time-barred |
Key Cases Cited
- Heimeshoff v. Hartford Life & Acc. Ins. Co., 571 U.S. 99 (limitations period in ERISA-governed plan is enforceable if reasonable)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards; plausibility required)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standards; plausibility and dismissal standard)
- Hale v. King, 642 F.3d 492 (5th Cir. pleading/plausibility discussion)
- Isquith ex rel. Isquith v. Middle S. Util., Inc., 847 F.2d 186 (5th Cir. discretion to consider matters outside the pleadings on Rule 12(b)(6))