Sepulveda-Rodriguez v. Metropolitan Life Insurance Co., No. 18-1760 (8th Cir. 2019)
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MetLife and Ford appealed the district court's award of benefits, costs and attorney fees in an Employee Retirement Income Security Act (ERISA) action. In this case, while MetLife paid plaintiff her husband's basic life insurance benefit, it denied payment of an optional life insurance (OLI) benefit.
The Eighth Circuit affirmed in part and reversed in part, holding that the district court erred in finding that there was no substantial evidence supporting MetLife's denial of OLI benefits, because substantial evidence supported MetLife's assertion that the husband answered an online questionnaire averring that he had not been treated for high blood pressure, when in fact he had. The court also held that there was substantial evidence in the record to support MetLife's reliance upon the plan administrator's representations that the husband would not have been automatically enrolled in the OLI program if he had truthfully answered the high blood pressure question in the screening questionnaire; the OLI benefits could not have been awarded on an equitable estoppel theory; the district court did not abuse its discretion by denying statutory penalties for the delay in providing documents; and attorney fees and costs must be reversed and remanded.
Court Description: Beam, Author, with Colloton and Shepherd, Circuit Judges] Civil Case - ERISA. Ford Motor Company, as employer, and Metropolitan Life Insurance Company, as issuer and claims administrator, appeal grant of optional life insurance benefits (OLI), costs, and attorneys fees. Employee was enrolled in OLI benefit program after falsely completing online questionnaire that he had not been diagnosed or treated for high blood pressure. After employee died of hypertensive and heart disease, the OLI benefits were denied. The district court awarded benefits finding denial of benefits was an abuse of discretion because documents were inadequate to show employee misrepresented prior medical history, and awarded statutory penalties, and attorneys fees. District court erred in finding there was not substantial evidence to support denial of benefits, as there was ample evidence to support that had employee been not been truthful and would not have been automatically enrolled had he been truthful. Not entitled to equitable estoppel remedy. Statutory penalties for delay in providing documents is upheld; attorneys fee and costs are reversed.
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