Salyers v. Metropolitan Life Insurance Co., No. 15-56371 (9th Cir. 2017)
Annotate this CaseThe Ninth Circuit reversed the district court's judgment in favor of MetLife in an action filed by plaintiff to seek life insurance benefits under a benefits plan governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The panel held that MetLife waived the evidence of insurability requirement because it did not ask plaintiff for a statement of health, even as it accepted her premiums for $250,000 in coverage. In this case, MetLife's purported ignorance of the facts did not negate its obligation to pay the entire $250,000 because, under agency law, the policyholder-employer's knowledge and conduct may be attributed to MetLife.
Court Description: Employee Retirement Income Security Act. The panel reversed the district court’s judgment in favor of the defendant following a bench trial in an ERISA action concerning life insurance. The plaintiff bought a $250,000 life insurance policy on her husband, but the defendant insurer paid out only $30,000 because the plaintiff had not submitted evidence of insurability with her coverage election, as required under the ERISA-governed benefits plan. The panel held that the defendant waived the evidence of insurability requirement because it did not ask the plaintiff for a statement of health, even as it accepted her premiums for $250,000 in coverage. The panel held that, under the federal common law of agency, the knowledge and conduct of the policyholder- employer could be attributed to the defendant. The panel remanded the case to the district court with instructions to enter judgment in favor of the plaintiff for the amount of the $250,000 policy that remained unpaid.
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