Babin v. Quality Energy Services, Inc., No. 17-30059 (5th Cir. 2017)Annotate this Case
Babin, employed by Quality, developed carpal tunnel syndrome and had several surgeries. Three months after he returned to work, his employment ended. Babin participated in Quality’s employee benefit plan, which provided short- and long-term disability benefits, governed by the Employee Retirement Income Security Act (ERISA). Babin submitted a short-term disability benefits application to Standard, Quality’s insurer. In February 2013, Standard denied Babin’s claim because it had not received a necessary form from Quality. Babin alleges that he provided that form to Quality, which failed to complete it. In February 2014, Babin’s counsel asked Quality for disability plan documents. Babin claims that Quality did not send those documents before he filed suit, that he believed that the short-term plan provided six months of benefits, and, had he known that the plan only provides three months of benefits, he would have applied for long-term benefits; Quality’s failure to produce the documents caused him to miss the window for long-term benefits. Babin filed suit 20 months after requesting the documents, alleging failure to produce documents and failure to pay benefits. The parties settled the denial-of-benefits claim. The court held that Louisiana’s one-year prescriptive period for delictual claims applies to 29 U.S.C. 1132(c) claims, so Babin’s claim was time-barred. The Fifth Circuit affirmed, rejecting Babin’s argument that Louisiana’s 10-year prescriptive period for personal actions should govern his claim for failure to produce documents.
The court issued a subsequent related opinion or order on January 4, 2018.