Silva v. Metropolitan Life Ins. Co., et al., No. 13-2233 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit against his deceased son's employer and the insurer, MetLife, under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq, after plaintiff was denied benefits of the son's life insurance policy. The court reversed the district court's grant of summary judgment to defendants on plaintiff's section 1132(a)(1)(B) claim where there were outstanding questions of material fact regarding whether MetLife abused its discretion when it denied benefits because the plan did not define evidence of insurability; reversed the denial of plaintiff's motion to add a claim under section 1132(a)(3); and remanded to the district court so that plaintiff has a full opportunity to litigate both his ERISA claims.
Court Description: Civil Case - ERISA. Benefits under a supplemental life insurance policy were denied for failure to submit evidence of insurability and district court granted summary judgment to plan fiduciary and employer. Because plan did not define evidence of insurability and any required form was not in the record, questions of material fact prevent review of whether MetLife abused its discretion in denying claims for benefits. District court's denial of motion to amend the complaint to add an additional ERISA claim under 29 U.S.C. sec. 1132(a)(3) because claim would be futile is reversed, as Silva could show an equitable claim of surcharge, reformation, or equitable estoppel. Silva is not precluded from pleading claims under section 1132(a)(1)(B) and 1132(a)(3) in motion to dismiss stage. Judge Gruender concurs in part and dissents in part.
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