Witt v. Metropolitan Life Insurance Co., et al., No. 14-11349 (11th Cir. 2014)Annotate this Case
Plaintiff filed suit against MetLife, the administrator of a long-term disability insurance plan subject to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., seeking to recover disability benefits. The court concluded that the six-year limitations period began to run on plaintiff's ERISA claim when the cause of action accrues; plaintiff's ERISA complaint in 2012 for benefits from May 1, 1997 forward is time-barred; the court rejected plaintiff's argument that his submission of post-1997 documentation is a new claim for benefits; and MetLife did not waive any defense based on the statute of limitations by failing to specify untimeliness as a basis for denying the claim after its courtesy review. Accordingly, the court affirmed the district court's grant of summary judgment.