Exhaustion of Administrative Remedies

Yates v. Symetra Life Ins. Co., No. 22-1093, __ F.4th __, 2023 WL 2174840 (8th Cir. Feb. 23, 2023) (Before Circuit Judges Shepherd, Kelly, and Grasz)

The “exhaustion of administrative remedies” doctrine – which requires benefit plan claimants to pursue internal appeals before filing suit – is a staple in ERISA cases. The doctrine

McQuillin v. Hartford Life & Accident Ins. Co., No. 21-1514, __ F. 4th __, 2022 WL 2029879 (2d Cir. Jun. 7, 2022) (Before Circuit Judges Walker, Calabresi, and Cabranes).

 ERISA claims administrators and courts often hold plan participants and beneficiaries strictly to time limits and other plan-imposed or regulatory requirements and cut off their rights when they fail to meet these requirements. In this decision, the Second Circuit rules that insurance companies and other claims administrators must likewise meet regulatory time limits or suffer the consequences of their failure to do so.
Continue Reading Taking ERISA Rights Seriously: Second Circuit Rules That Hartford’s Failure to Meet Time Limits Excuses Claimant from Exhaustion

Good morning, ERISA Watchers!  I hope this finds you well and in good spirits.  This week’s notable decision, Wallace v. Oakwood Healthcare, Inc., No. 18-2316, __F.3d__, 2020 WL 1522833 (6th Cir. Mar. 31, 2020), involves something we might all be feeling these days: exhaustion.  

Wallace involves a challenge to a denied long-term disability benefit claim.  Plaintiff was a registered nurse who was a participant in an ERISA-governed employee welfare benefit plan sponsored by her employer (“the Plan”). She stopped working in 2012 while the Plan was insured by Hartford Life & Accident Insurance Company. On January 1, 2013, the Plan shifted its contract to Reliance Standard. Plaintiff tried to return to work in 2013, but quickly went back on medical leave. She subsequently submitted a claim for benefits to Reliance, who denied it on the ground that she had a pre-existing condition that barred coverage. Plaintiff also submitted a claim to Hartford, who denied that as well. She appealed the Hartford denial, but did not appeal the Reliance denial before filing suit against Reliance.
Continue Reading Sixth Circuit Holds Exhaustion of Administrative Remedies Not Required Where Plan Document Is Silent on Claims Review Process