Santana-Diaz v. Metropolitan Life Ins. Co., No. 15-1273 (1st Cir. 2016)Annotate this Case
Appellant participated in Shell Chemical Yabucoa, Inc.’s employee welfare benefit plan, which Shell provided through a group insurance policy issued by Metropolitan Life Insurance Company (MetLife). On November 23, 2008, Appellant received his first long-term disability benefit payment. On April 5, 2010, Metlife sent Appellant a letter informing him that his benefits would expire on November 22, 2010. On November 24, 2010, in another letter, MetLife denied Appellant’s claim for an extension of benefits. On August 19, 2011, MetLife issued a final denial letter. Neither the November 24, 2010 letter nor the August 19, 2011 letter included a time period for filing suit. On August 18, 2013, Appellant filed suit, alleging improper denial of benefits. The district court dismissed the complaint as time-barred. The First Circuit reversed, holding (1) if a plan administrator fails to include the time limit for filing suit in its denial of benefits letter, the plan administrator is not in substantial compliance with Employee Retirement Income Security Act regulations, and the violation is per se prejudicial to the claimant; and (2) as a consequence of MetLife’s failure to include the time limit for filing suit in its final denial letter, the limitations period was rendered inapplicable, and therefore, Appellant’s suit was timely filed. Remanded.
The court issued a subsequent related opinion or order on March 24, 2016.