Jones v. Aetna Life Insurance Co., No. 16-1714 (8th Cir. 2017)
Annotate this CasePlaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., for denial of benefits and breach of fiduciary duty. The district court dismissed the fiduciary claim as duplicative of the denial-of-benefits claim, and granted summary judgment against plaintiff on the denial-of-benefits claim. The Eighth Circuit explained that this court's cases conflict about whether a participant or beneficiary bringing a section 1132(a)(1)(B) claim "to recover benefits due to him under the terms of his plan" may also bring a section 1132(a)(3) claim to obtain benefits. The Eighth Circuit held that Silva v. Metropolitan Life Insurance Co. was controlling in this case, where an (a)(1)(B) claimant may seek relief under (a)(3); because the two claims in this case assert different theories of liability, the court reversed as to the (a)(3) claim; Aetna's no-disability determination as to the (a)(1)(B) claim was reasonable and the court rejected plaintiff's arguments to the contrary; the district court correctly struck the Supplemental Administrative Record materials that were not before the plan administrator when it made its discretionary determination; and the court declined to consider plaintiff's remaining arguments. Accordingly, the Eighth Circuit affirmed in part, reversed in part, and remanded for further proceedings.
Court Description: Benton, Author, with Smith, Chief Judge, and Wollman, Circuit Judge] Civil case - ERISA. This court's cases conflict about whether a plan participant or beneficiary bringing a Section 1132(a)(1)(B) claim to recover benefits due her under the terms of the plan may also bring a Section 1132(a)(3) claim to obtain benefits as other appropriate equitable relief for a breach of fiduciary duty by a plan administrator; the two claims assert different theories of liability and a plan participant or benefit can file an action raising both claims; as a result, the district court erred in dismissing plaintiff's Section 1132(a)(3) claim, and the dismissal is reversed; with respect to the district court's order granting defendant summary judgment on plaintiff's Section 1132(a)(1)(B) claim, the plan's determination that plaintiff was not disabled was not unreasonable and the summary judgment is affirmed. Reversed in part, affirmed in part and remanded for further proceedings.
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