Kristina Powell v. Minnesota Life Insurance Co., No. 22-2096 (8th Cir. 2023)
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Plaintiff sued Minnesota Life Insurance Company and Securian Life Insurance Company, alleging that their denial of her claim for life insurance benefits violated the Employee Retirement Income Security Act (“ERISA”). The district court dismissed her complaint under the Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim.
The Eighth Circuit affirmed. The court concluded that the district court properly dismissed Plaintiff’s Section 1132(a)(3) claim. First, her contention that Minnesota Life and Securian failed to notify her husband of his conversion right does not amount to a breach of fiduciary duty because the terms of her husband’s policy did not require notice, and Plaintiff points to no provision of ERISA that would require such notice. Second, her assertion that Minnesota Life and Securian misrepresented that her husband’s conversion window would be extended rests on a misreading of the February 24 letter; Minnesota Life and Securian made no such representation.
Court Description: [Gruender, Author, with Benton and Shepherd, Circuit Judges] Civil case - ERISA. A letter the insurer sent after it had not notified plaintiff's decedent of his right to convert his policy did not modify the terms of the Plan; nor did the letter extend the original conversion period which had expired; the new period of conversion it did offer did not apply because plaintiff's decedent died outside of the new window for conversion; the district court properly dismissed plaintiff's Section 1132(a)(3) claim as the failure to notify decedent of his conversion rights was not a breach of fiduciary duty as neither the plan documents nor ERISA require such a notice.
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