LeGras v. AETNA Life Ins. Co., No. 12-56541 (9th Cir. 2015)
Annotate this CasePlaintiff filed suit against AETNA under the civil enforcement provision of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132. AETNA had denied plaintiff's application for continued long-term disability benefits and allowed plaintiff to file an internal appeal within 180 days. The district court dismissed the action for failure to exhaust administrative remedies. The court reversed, holding that because the last day of the appeal period fell on a Saturday, neither that day nor Sunday count in the computation of the 180 days. In this case, because plaintiff mailed his notice of appeal on Monday, it was timely. The court concluded that this method of counting time is widely recognized and furthers the goals and purposes of ERISA. and therefore, the court adopted it as part of ERISA’s federal common law.
Court Description: ERISA. The panel reversed the district court’s dismissal of an action challenging the denial of an application for continued long-term disability benefits under the Employee Retirement Income Security Act. The panel held that the district court erred in dismissing the action for failure to exhaust administrative remedies. The plaintiff’s internal appeal from the denial of his benefits application was denied as untimely under a 180-day appeal period. The panel held that the plaintiffs’ notice of internal appeal was timely because it was filed on the Monday after the Saturday on which the 180-day period ended. The panel adopted this method of counting time as part of ERISA’s federal common law. Dissenting, Judge N.R. Smith wrote that as a matter of contract interpretation, the plaintiff’s administrative appeal was untimely. LEGRAS V. AETNA LIFE INS. CO. 3
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