Tetreault v. Reliance Standard Life Ins. Co., No. 13-2353 (1st Cir. 2014)
Annotate this CasePlaintiff received benefits under her employer’s long-term disability benefit plan before the administrator for the long-term disability program determined she was no longer eligible for benefits. The administrator denied Plaintiff’s appeal as untimely for her failure to appeal within the benefit plan’s 180-day deadline. Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), claiming that her failure to comply with the 180-day deadline should have been excused because the benefit plan’s written instrument did not mention the deadline. The district court dismissed Plaintiff’s benefits challenge as well as her two other ERISA claims for statutory penalties and for breach of fiduciary duty. The First Circuit affirmed, holding that the district court did not err in (1) dismissing Plaintiff’s benefits challenge, as Plaintiff failed to meet the deadline for appealing internally the decision to cut off her long-term disability benefits, and the benefit plan had expressly incorporated that deadline into the benefit plan’s written instrument; and (2) ruling that Plaintiff could not recover statutory penalties against the administrator or that she had waived her claim for breach of fiduciary duty.
The court issued a subsequent related opinion or order on October 24, 2014.
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