Jones v. Aetna Life Insurance Co., No. 16-1714 (8th Cir. 2017)Annotate this Case
Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., for denial of benefits and breach of fiduciary duty. The district court dismissed the fiduciary claim as duplicative of the denial-of-benefits claim, and granted summary judgment against plaintiff on the denial-of-benefits claim. The Eighth Circuit explained that this court's cases conflict about whether a participant or beneficiary bringing a section 1132(a)(1)(B) claim "to recover benefits due to him under the terms of his plan" may also bring a section 1132(a)(3) claim to obtain benefits. The Eighth Circuit held that Silva v. Metropolitan Life Insurance Co. was controlling in this case, where an (a)(1)(B) claimant may seek relief under (a)(3); because the two claims in this case assert different theories of liability, the court reversed as to the (a)(3) claim; Aetna's no-disability determination as to the (a)(1)(B) claim was reasonable and the court rejected plaintiff's arguments to the contrary; the district court correctly struck the Supplemental Administrative Record materials that were not before the plan administrator when it made its discretionary determination; and the court declined to consider plaintiff's remaining arguments. Accordingly, the Eighth Circuit affirmed in part, reversed in part, and remanded for further proceedings.