The U.S. District Court for the Eastern District of Louisiana grants the motion for summary judgment by the defendant disability insurance claims administrator for a claim of miscalculation of disability benefits.
The plaintiff is an employee of a financial services company who receives a monthly long-term disability (LTD) benefit pursuant to a group insurance policy governed by the Employee Retirement Income Security Act of 1974 (ERISA). The defendant is the insurance company that acts as the policy administrator. The plaintiff suffered from a work-related injury in June 2006 and filed a claim under the policy for LTD benefits. The claim was approved by the defendant in March 2008. Along with the approval, the defendant sent the plaintiff a letter informing him of his monthly benefit and an explanation of how it was calculated. The plaintiff did not question the calculation until June 2017, at which time he filed an administrative challenge alleging a miscalculation of the benefit amount. The defendant denied the challenge, and the plaintiff filed suit.
The defendant filed a motion for summary judgment, arguing that the plaintiff's lawsuit is untimely. The policy has a three-year statute of limitations requiring a suit to be filed within three years of when a proof of claim is required. Because the proof of claim was required by March 2, 2007, the defendant argues that a suit had to be filed by March 2, 2010. This lawsuit was not filed until June 2017.
A participant and an ERISA-regulated plan may contractually agree to a particular limitations period, even one that starts to run before the cause of action accrues, as long as the period is reasonable and there is no controlling statute that prevents the limitations period from taking effect. The plaintiff argues that the limitations period of the policy is unreasonable in light of the facts pertaining to his miscalculation claim.