Opinion
CIVIL ACTION NO. 05-12167-RWZ.
October 29, 2007
MEMORANDUM OF DECISION AND ORDER
I. Introduction
Plaintiff Tammy Keiffer ("Keiffer") brings this action challenging a plan administrator's decision to deny her claim for optional life insurance benefits under an employee welfare benefit plan. For the reasons discussed below, I find that the denial of benefits was not arbitrary and capricious and therefore allow defendants' motion for summary judgment and deny plaintiff's corresponding motion.
The life insurance at issue is at times referred to by the parties as either "optional" or "supplemental." The court will refer to the insurance as "optional" for the sake of simplicity.
II. Background and Procedural History
Plaintiff's deceased husband, Edward Keiffer ("the Decedent") was employed for several years by the IT Group, Inc., which provided an employee group welfare plan governed by the Employee Retirement Income Security Act of 1974 ("ERISA"), as amended, 29 U.S.C. §§ 1001- 1461. In July 2002, The Shaw Group, Inc. ("Shaw") purchased IT Group and rolled the IT Group's plan into The Shaw Group, Inc. Employee Welfare Plan ("Plan"), which is also governed by ERISA. Defendant Metropolitan Life Insurance Company ("MetLife") is the claims fiduciary for the Plan. The Plan gives MetLife discretion to interpret the terms of the Plan and to determine eligibility for and entitlement to Plan benefits.
The Plan provides:
In carrying out their respective responsibilities under the Plan, the Plan administrator and other Plan fiduciaries shall have discretionary authority to interpret the terms of the Plan and to determine eligibility for and entitlement to Plan benefits in accordance with the terms of the Plan. Any interpretation or determination made pursuant to such discretionary authority shall be given full force and effect, unless it can be shown that the interpretation or determination was arbitrary and capricious.
(MetLife claim file (Docket # 27) at MET0073.) Further references to MetLife's claim file will simply refer to the MET#### page number.
The Decedent participated in the Plan and selected optional life insurance benefits. In late September 2002, the Decedent committed suicide. Plaintiff subsequently submitted a claim for optional life insurance benefits. MetLife rejected the claim, relying upon a provision in the Plan's documents that excludes coverage if the insured "commit[ed] suicide, while sane or insane, within 2 years from the effective date of this certificate." (MET0034.) MetLife determined that the effective date of the Decedent's optional life insurance coverage under its certificate was January 1, 2001, less than two years before the Decedent's suicide. Plaintiff twice requested review of her claim under MetLife's procedures, and MetLife twice affirmed its denial, most recently in a letter dated October 27, 2003.
Plaintiff challenged MetLife's determination in a five-count complaint filed in Massachusetts state court in July 2005, alleging claims under ERISA, negligence, and breach of contract. Defendants timely removed the case to federal court. This court dismissed the negligence and breach of contract claims on July 14, 2006. The parties have filed cross-motions for summary judgment on the remaining ERISA claims.
Plaintiff's complaint also named Shaw as a defendant with regard to the negligence and breach of contract counts. Shaw was accordingly dismissed from the action when those counts were dismissed.
III. Legal Standards
A. Standard of Review
"Where, as here, a plan administrator has discretion to determine eligibility for and entitlement to benefits, the district court must uphold the administrator's decision `unless it is arbitrary, capricious, or an abuse of discretion.'" Glista v. Unum Life Ins. Co. of Am., 378 F.3d 113, 125 (1st Cir. 2004) (quoting Gannon v. Metro. Life. Ins. Co., 360 F.3d 211, 212-13 (1st Cir. 2004)). On arbitrary and capricious review, the administrator's decision will be upheld if the denial is "reasonable and supported by substantial evidence." Id. Substantial evidence does not require that there be no contradictory evidence, only that the evidence is sufficient to reasonably support the administrator's conclusion. Doyle v. Paul Revere Life Ins. Co., 144 F.3d 181, 184 (1st Cir. 1998). "It is, of course, the hallmark of such review that a court is not to substitute its judgment for that of the [decision-maker]." Terry v. Bayer Corp., 145 F.3d 28, 40 (1st Cir. 1998) (internal quotation marks and citation omitted).
B. Summary Judgment
Summary judgment is appropriate when "there is no genuine issue as to any material fact," and "the moving party is entitled to judgment as a matter of law." Fed.R.Civ.P. 56(c). In ERISA actions, summary judgment is "simply a vehicle for deciding the issues." Orndorf v. Paul Revere Life Ins. Co., 404 F.3d 510, 517 (1st Cir. 2005). This is because "the district court sits more as an appellate tribunal than as a trial court. It does not take evidence, but rather, evaluates the reasonableness of an administrative determination in light of the record compiled before the plan fiduciary." Leahy v. Raytheon Co., 315 F.3d 11, 17 (1st Cir. 2002).
IV. MetLife's Decision to Deny Benefits
Keiffer filed a claim for life insurance benefits at the end of October 2002. MetLife paid Keiffer basic life insurance benefits, but it denied her claim for optional life insurance benefits in a letter dated December 13, 2002. The letter referenced the Plan's suicide provision, that such benefits will not be paid if the employee commits suicide within two years from the effective date of the enrollment certificate. The parties disagree as to the date on which the Decedent enrolled. MetLife, based on Shaw's records, determined the date to be January 1, 2001, less than two years before his suicide.
Plaintiff stated in her appeal to MetLife that she believed the Decedent had possessed optional life insurance coverage prior to October 2000 and had continued it. She posited that if he was not covered, the optional life insurance was "erroneously cancelled by other persons." (MET0440.)
MetLife again reviewed the Decedent's file, which was maintained by Shaw, and found no indication that he had participated in the optional life insurance plan for the calendar year 2000. MetLife therefore upheld its denial of benefits. It so informed plaintiff by letter, dated January 10, 2003, which included the records provided by Shaw for the benefit years 2000-2002. These records reflected the Decedent's election of only basic life insurance coverage for calendar year 2000, but optional coverage for calendar years 2001 and 2002. MetLife also reported in the letter that it had spoken with the Shaw employee who maintained the records. The employee stated that Shaw sends a confirmation statement to the employee after enrollment, and the employee is given thirty days to contact Shaw with any changes. The employee did not have any record of the Decedent contacting Shaw to report a problem with his enrollment for the year 2000.
Keiffer again asked MetLife to review its decision, by letter dated February 26, 2003. She enclosed her correspondence with Shaw in October 2002, which gave the following reasons for her belief that her husband never intended to discontinue optional life insurance benefits:
• The Decedent consistently elected optional life insurance coverage beginning in 1993, and the only years the available records did not show optional coverage were 1999 and 2000; • In 1999 and 2000 the policy for electing benefits changed, and the procedures in place during those years were inaccurate; • The Decedent was meticulous about maintaining his financial records, but Keiffer did not have confirmation statements for either 1999 or 2000; • The Decedent kept Keiffer informed of financial decisions. MetLife again investigated Keiffer's claim, and again denied it, by letter dated October 27, 2003. In the letter MetLife describes its review and analysis of various documents obtained from Shaw. The documents included copies of printouts, titled "Single Plan Entries," concerning the Decedent's enrollment for benefits in 1999, 2000 and 2001 for, respectively, the calendar years 2000, 2001 and 2002. The Single Plan Entry for December 18, 1999, showed that the Decedent enrolled only for basic life insurance for 2000. In contrast, the Single Plan Entries for 2000 and 2001 showed that the Decedent enrolled in both basic and optional insurance for 2001 and 2002. The letter further stated that the Single Plan Entries indicated that the Decedent had optional life insurance coverage in 1993 and 1995, but that Shaw's records did not contain any information about the Decedent's enrollments for 1994, 1996, 1997 and 1998.Also included were copies of Shaw's historical payroll register for the Decedent for the years 1999 to 2002, which showed the deductions taken from the Decedent's pay for benefits for each of those years. According to Shaw, from 1999 to 2001 payments for optional life insurance were included with post-tax payroll deductions. In 2002, payments were included with pre-tax payroll deductions. The Decedent's records indicated that deductions in 1999 and 2000, when the Decedent did not have optional coverage, were lower than deductions in 2001 and 2002, when the Decedent did have the optional coverage. According to MetLife, Shaw did not attribute the increase in deductions in 2001 and 2002 to anything but enrollment for optional life insurance.
Apparently the Decedent did not receive confirmations of enrollment in optional coverage for 1999 and 2000. Plaintiff deems this to support her position that an administrative error was responsible. MetLife points out, however, that it is entirely consistent with its position that he was not enrolled in optional coverage during that time.
V. Discussion
There is no dispute that the suicide provision in the Plan operates to bar Keiffer's claim if the Decedent was not enrolled in optional life insurance in October 2000. The parties disagree as to the date on which the Decedent was covered, specifically whether he was enrolled in October 2000. MetLife relied on the records incident to the Decedent's employment by IT Group and Shaw, which support its determination that he was not enrolled at the critical date.
Plaintiff claims, in substance, that the Decedent intended to enroll in the years in question and was thwarted by administrative mismanagement of the Plan. The difficulty for plaintiff is that nothing in the record supports her hypothesis, and such evidence as is contained therein points to his failure to take the necessary steps to enroll. Keiffer submitted no documentary evidence to MetLife of the Decedent's intent or belief that he had enrolled in supplementary benefits in either 1999 or 2000. Although Keiffer claims that IT Group's telephone enrollment system was inaccurate, the only evidence in the file supporting this claim is an email that is, at best, ambiguous, as (1) it states that the system works, and (2) it is from May 2000, long after the enrollment for calendar year 1999, which occurred in late 1998. (See MET0418.) A Single Plan Entry for September 25, 1998 is ambiguous, as it shows enrollment in optional life insurance for the 1997 year.
Plaintiff asserts that the Decedent's enrollment for calendar year 1999 is relevant because he did not make any changes to his enrollment for calendar year 2000, and his 1999 choices accordingly "rolled over" to the 2000 calendar year under the terms of the IT Group's benefits policy.
It is also notable that the benefit enrollment forms for 2000, 2001 and 2002 all defined the enrollment periods as occurring in either late October or early November, not in September. (See MET0413, MET0419, MET0422.)
VI. Conclusion
The court reiterates that its role in this review is not to balance the equities of the parties or come to a "fair" determination. The review is limited to determining whether MetLife had sufficient grounds for concluding that the Decedent was not enrolled in optional life insurance coverage prior to October 2000. The administrative file fully supports MetLife's conclusion and consequent denial of benefits. Accordingly, its decision must stand.
For the reasons stated above, defendants' motion for summary judgment (Docket # 31) is ALLOWED. Keiffer's motion for summary judgment (Docket # 33) is DENIED. Judgment may be entered for defendants.