Riley v. Metro. Life Ins., No. 13-2166 (1st Cir. 2014)Annotate this Case
Plaintiff, who worked for Metropolitan Life Insurance Co. (“MetLife”), made a claim for long-term disability benefits (LTD). In 2005, the claim was approved. That same year, MetLife denied Plaintiff’s assertion that he was entitled to a larger payment calculation. In 2012, Plaintiff filed suit against MetLife under the Employee Retirement Income Security Act of 1974 (ERISA), claiming that MetLife had been underpaying his monthly benefits since 2005. The district court granted MetLife’s motion for summary judgment, concluding that Plaintiff’s suit was barred by the six-year statute of limitations. The First Circuit Court of Appeals affirmed, thus rejecting Plaintiff’s theory that the LTD plan must be analogized to an installment plan so as to alter the accrual date of his claim, holding that Plaintiff’s claim against MetLife was barred by the statute of limitations.