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Claims Administrator Did Not Wrongly Deny Benefi ts to Ex-Employee, Seventh Circuit Rules

Tolle, Norman L

Employee Relations Law Journal, 2017-10, Vol.43 (2), p.103

New York: Aspen Publishers, Inc

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  • Título:
    Claims Administrator Did Not Wrongly Deny Benefi ts to Ex-Employee, Seventh Circuit Rules
  • Autor: Tolle, Norman L
  • Assuntos: Bankruptcy ; Disability pensions ; District courts ; Employees ; ERISA ; Federal court decisions ; Federal courts ; Fiduciary responsibility ; Insurance policies ; Labor law ; Life insurance companies ; Litigation ; Retirement benefits ; State court decisions
  • É parte de: Employee Relations Law Journal, 2017-10, Vol.43 (2), p.103
  • Descrição: [...]the circuit court rejected the plaintiff's argument that it should award him "appropriate equitable relief" because MetLife had breached its fiduciary duties to him. According to the circuit court, a denial of benefits, without more, did "not constitute a breach of fiduciary duty" that could be remedied under the "equitable-relief" provision of ERISA. According to the plaintiff, she withdrew her LTD benefits claim with Reliance because ARH had informed her that the "application for and approval of LTD benefits the plaintiff] had impairments that would render him disabled as of 12/09/03." In its decision, the district court explained that the plaintiff alleged a disability onset date of December 9, 2003 and that the 90-day "elimination period" (90 days of continual disability) ran from December 9, 2003 to March 8, 2004. [...]the district court continued, the plan required that the plaintiff provide UNUM with written proof of his claim by June 7, 2004 (90 days after his elimination period). The district court noted that the plaintiff fi rst applied for benefits under the plan on June 22, 2011-more than six years "after the latest conceivable date" the plan would have allowed him to submit proof of his claim. [...]the district court ruled, the plaintiff failed to timely comply with the plan's proof of claim requirement. [...]the district court concluded, the plaintiff had not acted with reasonable diligence, and he had not presented a sufficient basis for equitable relief from the plan requirements.
  • Editor: New York: Aspen Publishers, Inc
  • Idioma: Inglês

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