Statute of Limitations for Underpayment of TDI Benefits

In a claim of underpayment of long-term disability benefits, the statute of limitations accrues at the time the underpayment is made known to the participant when (s)he receives his first miscalculated benefit award and not with each monthly benefit payment made, the First Circuit Court of Appeals ruled this month in Riley v. Metro. Life Ins. Co., 2014 WL 814742 (1st Cir. Mar. 4, 2014).

In 2012, plaintiff Robert Riley filed suit under the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1001 et seq. , against defendant Metropolitan Life Insurance Co. (“MetLife”), arguing that MetLife had been underpaying his monthly benefits since its 2005 denial of his assertion that he was entitled to a larger payment calculation under his long-term disability insurance plan. The district court granted MetLife’s motion for summary judgment on the grounds that Riley’s suit was barred by the six-year statute of limitations. See Riley v. Metro. Life Ins. Co. , ___ F. Supp. 2d ___, 2013 WL 5009618 (D. Mass. Sept. 11, 2013). We affirm, rejecting Riley’s argument that this long-term disability plan must be analogized to an installment payment plan so as to alter the accrual date of his claim. In doing so, we join three other circuits. We also reject his claim that the plan documents here create a different accrual rule for him based on a principle of “symmetry” and reject his equitable arguments.

Read the full opinion here.

Advertisements

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s