Hall v. Metropolitan Life Ins., et al.

Plaintiff filed suit against MetLife, alleging that MetLife abused its discretion in denying her claim to receive the proceeds of her late husband's life insurance policy under an employee-benefit plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. On appeal, plaintiff challenged the district court's grant of summary judgment to MetLife. The court concluded based on the evidence - the 1991 form, the husband's will, and the November 2010 form - that MetLife did not abuse its discretion in determining that the husband's son, rather than plaintiff, was the beneficiary of the life insurance proceeds. Even assuming that the substantial-compliance doctrine was available to federal courts in the interpleader context, the court would not extend it to the circumstances presented here. Where an ERISA plan administrator is given discretion under the plan to determine eligibility for benefits, the doctrine does not deprive the administrator from requiring strict compliance with the terms of the plan. Accordingly, the court affirmed the judgment of the district court. View "Hall v. Metropolitan Life Ins., et al." on Justia Law