Santana-Díaz v. Metro. Life Ins. Co.
| Decision Date | 14 March 2016 |
| Docket Number | No. 15–1273.,15–1273. |
| Parties | Dionisio SANTANA–DÍAZ, Plaintiff, Appellant, v. METROPOLITAN LIFE INSURANCE COMPANY, Defendant, Appellee. |
| Court | U.S. Court of Appeals — First Circuit |
Efrain Maceira–Ortiz, for appellant.
Frank Gotay–Barquet, for appellee.
Before THOMPSON, HAWKINS,* and BARRON, Circuit Judges.
THOMPSON
, Circuit Judge.
In this appeal under the Employee Retirement Income Security Act of 1974 ("ERISA"), as amended, 29 U.S.C. §§ 1001
–1461, App ellant Dionisio Santana–Díaz ("Santana–Díaz") challenges the district court's dismissal of his suit as time-barred, arguing that he is entitled to equitable tolling, in part because the plan administrator, Appellee Metropolitan Life Insurance Company ("MetLife"), failed to include the time period for filing suit in its denial of benefits letter. We hold that ERISA requires a plan administrator in its denial of benefits letter to inform a claimant of not only his right to bring a civil action, but also the plan-imposed time limit for doing so. Because MetLife violated this regulatory obligation, the limitations period in this case was rendered inapplicable, and Santana–Díaz's suit was therefore timely filed. Accordingly, we reverse and remand.
We begin by summarizing the facts relevant to this appeal. Santana–Díaz was a financial analyst and ten-plus-year employee at Shell Chemical Yabucoa, Inc. ("Shell Chemical").1 He participated in Shell Chemical's employee welfare benefit plan (the "Plan"), which Shell Chemical provided through a group insurance policy issued by MetLife. Beginning in November 2007, Santana–Díaz, who suffered from major depression
, high blood pressure, asthma, and various other physical and mental ailments, claimed and received sick leave and then short-term disability leave. Santana–Díaz submitted his claim for long-term disability benefits on April 7, 2008, and in December 2008, received his first long-term disability benefit payment for the period beginning on November 23, 2008.
On April 5, 2010, MetLife sent Santana–Díaz a letter informing him that, although he was currently receiving long-term disability benefits, the maximum duration period for his particular disability was twenty-four months, and his benefits would therefore expire on November 22, 2010. As MetLife explained it, under the terms of the Plan, long-term disability benefits were limited to twenty-four months if the beneficiary's disability was the result of a "mental or nervous disorder or disease limitation." "[T]he primary diagnosis preventing [Santana–Díaz] from working [was] major depression
," MetLife said, which fell into that category; thus Santana–Díaz was entitled to long-term disability benefits only for the limited duration period. MetLife went on to explain that in order to continue receiving benefits beyond November 22, 2010, Santana–Díaz would have to submit additional documentation that showed his disability was not subject to the limitation.2
After receiving the April 5, 2010 letter, Santana–Díaz submitted various medical files and additional information. Upon reviewing the documents, MetLife denied Santana–Díaz's claim for an extension of benefits beyond the twenty-four-month limited period in a letter dated November 24, 2010. Santana–Díaz, proceeding pro se, filed an administrative appeal of the decision with the aid of his son, which MetLife likewise denied in an August 19, 2011 letter. Now this is important for our purposes today: both MetLife's November 24, 2010 initial denial of benefits letter and its August 19, 2011 final denial letter informed Santana–Díaz that he could bring a civil action, but neither letter included a time limit for doing so or mentioned at all that the right to bring suit was subject to a limitations period.
Nevertheless, the Plan—which Santana–Díaz had received when Shell Chemical first became his employer at least ten years prior—did contain a three-year limitations period that provided, in relevant part, that "[n]o legal action of any kind may be filed ... more than three years after proof of Disability must be filed." Under the terms of the Plan, the deadline for Santana–Díaz's proof of disability had been February 17, 2009 (and no, MetLife never mentions this start date in its letters either).3 According to MetLife, Santana–Díaz's time period for filing suit therefore expired three years thereafter.
Alas, Santana–Díaz, finally represented by counsel, did not file suit until August 18, 2013. The complaint alleged a 29 U.S.C. § 1132(a)
claim for improper denial of benefits. In a motion for summary judgment, MetLife argued the suit was filed a year-and-a-half too late. The district court agreed, granting the motion and dismissing Santana–Díaz's complaint as time-barred. Santana–Díaz now appeals, arguing that the district court erred in dismissing his case because MetLife's failure to provide notice of the time limit for filing suit in its final denial letter entitled him to equitable tolling.
We review the district court's grant of summary judgment de novo.Orndorf v. Paul Revere Life Ins. Co., 404 F.3d 510, 516 (1st Cir.2005)
.
ERISA itself does not contain a statute of limitations for bringing a civil action, see 29 U.S.C. § 1132(a)(1)(B)
, so federal courts usually "borrow the most closely analogous statute of limitations in the forum state." Santaliz–Ríos v. Metro. Life Ins. Co., 693 F.3d 57, 59 (1st Cir.2012), cert. denied, ––– U.S. ––––, 133 S.Ct. 1726, 185 L.Ed.2d 786 (2013). But where the employee benefit plan "itself provides a shorter limitations period, that period will govern as long as it is reasonable." Id. at 60. In this case, the Plan contained a three-year limitations period that ran from the date proof of disability was due. MetLife included no mention of this time limit in its final denial letter. The issue at the heart of this appeal is what impact such defective notice should have on a contractual limitations period. Before we turn to this question, however, we first briefly address Santana–Díaz's argument that the district court applied the wrong start date to the limitations period.4
Santana–Díaz's argument regarding the limitations period start date is anything but clear. He seems to want us to conclude that the three-year limitations period began to run on August 19, 2011, the date of the final denial letter, and not, as the Plan provides, on the date proof of disability was due.
Santana–Díaz argues that, because he was still receiving benefits on February 17, 2009, when proof of disability was due, he "had nothing to complain about," and had no reason to file suit. Thus, he says, it would be "clearly erroneous, patently unreasonable and will result in an unfair outcome" for the limitations period to have begun to run before he had suffered an actual injury. Santana–Díaz seems to suggest that perhaps the limitations period would, instead, have begun to run on November 24, 2010, when MetLife issued notice terminating his benefits. Except that date did not set off the limitations period either, he argues, because in that November 24, 2010 letter, MetLife stated: "In the event your appeal is denied in whole or in part, you will have the right to bring a civil action...." Santana–Díaz argues that this instruction to await the outcome of the administrative appeal before bringing a civil action, without any other mention in the letter of a time limit for filing suit, obscured from him the fact that the clock for filing was already ticking, and that, on that basis, we should conclude the limitations period actually only began to run on August 19, 2011, when his administrative appeal was denied. (Three years from either date, November 24, 2010, or August 19, 2011, though, would have rendered Santana–Díaz's August 18, 2013 complaint timely.)
Santana–Díaz never really clarifies in his brief whether he is challenging the enforceability of the limitations provision, raising an estoppel argument, or presenting some combination thereof, and we are not quite persuaded that, under any of these theories, Santana–Díaz would be able to get around the limitations period start date as it is written in the Plan.5 Regardless, it does not matter because, as we get to in a minute, we conclude MetLife's regulatory violation rendered the contractual limitations period in this case altogether inapplicable, and we therefore do not need to decide when that limitations period would have begun to run.
Santana–Díaz argues here, as he did below, that MetLife's final denial letter did not comply with 29 C.F.R. § 2560.503–1(g)(1)(iv)
because it failed to provide notice of the plan-imposed time limit for filing suit, and that, as a result, equitable tolling should apply.6 The district court disagreed, concluding that, even though MetLife had failed to provide notice, this failure did not entitle Santana–Díaz to the "extraordinary measure of equitable tolling" because Santana–Díaz "was made aware of both the time limit for plan participants to file legal action and how the plan calculates time, since these matters were clearly and explicitly laid out in the group policy." We need not determine whether the district court correctly decided this equitable tolling issue, however, because we begin and end our review with the issue of MetLife's failure to note the time period for filing suit in its final denial letter.
As we explain in the following sections, we conclude that, in failing to provide such notice, MetLife was not in substantial compliance with the ERISA regulations, and that this rendered the limitations period altogether inapplicable. Because this resolves the question of whether Santana–Díaz's claim was time-barred, we need not discuss whether the limitations period would otherwise have been equitably tolled.7
ERISA is a remedial statute intended "to ‘protect ... the interests of participants in...
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