Salyers v. Metropolitan Life Insurance Co., No. 15-56371 (9th Cir. 2017)Annotate this Case
The Ninth Circuit reversed the district court's judgment in favor of MetLife in an action filed by plaintiff to seek life insurance benefits under a benefits plan governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The panel held that MetLife waived the evidence of insurability requirement because it did not ask plaintiff for a statement of health, even as it accepted her premiums for $250,000 in coverage. In this case, MetLife's purported ignorance of the facts did not negate its obligation to pay the entire $250,000 because, under agency law, the policyholder-employer's knowledge and conduct may be attributed to MetLife.