Moore v. Metro. Life Ins. Co.
| Decision Date | 10 June 2013 |
| Docket Number | Civil Action No. 2:11cv170–MHT. |
| Parties | Janie MOORE, Plaintiff, v. METROPOLITAN LIFE INSURANCE CO.; et al., Defendants. |
| Court | U.S. District Court — Middle District of Alabama |
OPINION TEXT STARTS HERE
Miles Clayborn Williams, Thomas O'Neal Sinclair, Sinclair Williams, LLC, Birmingham, AL, for Plaintiff.
Summer Austin Davis, Thomas Matthew Miller, Bradley Arant Boult Cummings LLP, Birmingham, AL, Joclaudia Moore, William P. Cobb, II, Balch & Bingham LLP, Montgomery, AL, for Defendants.
Plaintiff Janie Moore filed this action against defendants Metropolitan Life Insurance Company; Southern Company Services, Inc.; and Group Life Insurance Plan, Dependent Life Benefits for Southern Company Services, Inc., and Associated or Affiliated Companies, claiming a violation of the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1001, et seq. and seeking to recover benefits pursuant to 29 U.S.C. § 1132(a)(1). Jurisdiction over Ms. Moore's federal claim is proper under 28 U.S.C. § 1331 (federal question). This case is currently before the court on a review of the insurance company's denial of benefits to Ms. Moore. For the reasons that follow, the court holds that Ms. Moore is entitled to benefits.
Ms. Moore worked for Alabama Power Company, a division of defendant Southern Company. As an employee, she participated in a dependent-life-benefits-group-insurance plan. Metropolitan Life serves as both the plan's administrator of claims as well as the payor of benefits.
The plan documents state that a claimant must submit proof satisfactory to Metropolitan Life to get a benefit under the plan. The plan defines “spouse” as “your lawful spouse,” and the plan administrator has “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.” Claims File—Part Two (Doc. No. 57–4) at 38. The plan states that any interpretation made under its discretionary authority shall have effect unless it was arbitrary and capricious. Id.
In 2003, Ms. Moore enrolled in the plan to secure $50,000 in dependent-life-insurance coverage for her common-law husband, Mr. Moore. In September of 2009, Mr. Moore died of lung cancer. After his death, Alabama Power submitted a claim for Ms. Moore to Metropolitan Life certifying that she had enrolled and had certifiable coverage and that Mr. Moore was her spouse. Claims File—Part One (Doc. No. 57–1) at 2–5.
As part of the claims process, Ms. Moore completed a common-law marriage questionnaire for Metropolitan Life. Id. at 14–23. On the questionnaire, she listed the address of the couple's shared rented residence, date the marriage began (1985), and the location of first cohabitation (Wisconsin). She also provided the names and contact information of three people who would affirm that they knew the Moores as husband and wife (of whom two had known the Moores for 23 years). She indicated that both she and Mr. Moore had listed “single” as their marital status on the last federal income-tax return. She provided the names and personal information of the three children the couple had conceived and raised together. She left three questions blank: those requesting information for joint checking, savings, and investment accounts.
Ms. Moore also voluntarily attached three documents to the questionnaire: an insurance policy from 2004 where Mr. Moore listed her as his spouse, a birth certificate for one of their children showing both Mr. and Ms. Moore as the parents, and a program from the decedent's funeral. After Ms. Moore sent all of this information to Metropolitan Life, she received a letter denying her claim.
In November 2009, Metropolitan Life notified Ms. Moore that, based on the documentation in her file, her claim was denied. Id. at 27–28. The initial denial letter states that “documentation within the claim file acknowledges that yourself [sic] and Mr. Moore were Common–Law spouses.” Id. at 27. The insurance company explained that, because the Moores' cohabitation began in Wisconsin—a State that does not recognize the validity of common-law marriage—it was denying the claim.
Ms. Moore appealed the decision in December 2009. Id. at 29. In her appeal letter, she stated that, although the Moores' cohabitation began in Wisconsin, they had been residing together permanently in Alabama since 1995 and thus did have a common-law marriage under Alabama law. Later that month, Metropolitan Life upheld its adverse-claim determination reiterating its earlier claim that: Id. at 34–35. The insurance company then addressed Ms. Moore's statement that it had applied the wrong State's laws, writing: Claims File—Part Two (Doc. No. 57–1) at 35 (emphasis added).
In August 2010, Ms. Moore again wrote Metropolitan Life requesting reconsideration of its denial. Claims File–Part Two (Doc. No. 57–2) at 4–5. She reasserted that Alabama—not Wisconsin—law applied and supplemented the items already submitted by laying out that the Moores had lived together as husband and wife for more that two decades. She reasserted that the couple had resided together permanently in Alabama since 1995, holding themselves out as married to those who knew them (she took his surname) and raised three children together (who all took the Moore name as well).
Without repudiating its earlier denial of benefits based on Wisconsin law, Metropolitan Life wrote to Ms. Moore requiring documents that it claimed could possibly substantiate a common-law marriage. Id. at 14. The insurance company required submission of at least two of the following three items: (1) documentation of a joint lease or deed; (2) documentation showing joint bank accounts, credit cards, or other investments; (3) a copy of federal-tax returns showing joint filing.
In December 2010, Ms. Moore notified Metropolitan Life that, absent a repudiation of its decision based on Wisconsin law or a final ruling on the appeal, she would not submit any more information. Id. at 26–27. The insurance company responded that same month with a letter stating that she had exhausted her administrative remedies under the Plan and that it would consider no further appeals. Id. at 31.
After litigation began in this case, Metropolitan Life conceded that Alabama law governs the couple's relationship. Id. at 33–34.
Ms. Moore challenges Metropolitan Life's denial of her claim for spousal-death benefits. She argues that she had a valid common-law marriage under Alabama law and that the insurance company erred in denying her spousal-death benefits. Metropolitan Life claims that Ms. Moore failed to submit satisfactory proof of a common-law marriage. The insurance company argues that its decision was correct, reasonable, and not affected by a conflict of interest.
This court must determine whether a reasonable basis existed for the ERISA plan administrator's benefits decision.
The court uses a modified version of the test articulated in Williams v. BellSouth Telecomm., Inc., 373 F.3d 1132, 1137–38 (11th Cir.2004). A court reviewing an ERISA-plan benefit denial must:
“(1) Apply the de novo standard to determine whether the claim administrator's benefits-denial decision is ‘wrong’ (i.e. the court disagrees with the administrator's decision); if it is not, end judicial inquiry and affirm the decision.
“(2) If the administrator's decision in fact is ‘de novo wrong,’ then determine whether he was vested with discretion in reviewing claims; if not end the judicial inquiry and reverse the decision.
“(3) If the administrator's decision is ‘de novo wrong’ and he was vested with discretion in reviewing claims, then determine whether ‘reasonable’ grounds supported it (hence, review his decision under the more deferential arbitrary and capricious standard).
“(4) If no reasonable grounds exist, then end the inquiry and reverse the administrator's decision; if reasonable grounds do exist, then determine if he operated under a conflict of interest.
“(5) If there is no conflict, then end the inquiry and affirm the decision.
“(6) If there is a conflict of interest, the conflict should merely be a factor for the court to take into account when determining whether an administrator's decision was arbitrary and capricious.”
Blankenship v. Metropolitan Life Ins. Co., 644 F.3d 1350, 1355 (11th Cir.2011); see also Capone v. Aetna Life Ins. Co., 592 F.3d 1189, 1195–96 (11th Cir.2010) ().
In other words, a denial of plan benefits is reviewed de novo unless the plan states otherwise. Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115, 109 S.Ct. 948, 103 L.Ed.2d 80 (1989). Where the plan provides discretionary authority to the administrator, an abuse-of-discretion standard is appropriate. Id. at 111, 109 S.Ct. 948;see also Metro. Life Ins. Co. v. Glenn, 554 U.S. 105, 111, 128 S.Ct. 2343, 171 L.Ed.2d 299 (2008). Review of the administrator's denial of benefits is limited to consideration of the materialavailable to the administrator at the time it made its decision. See Jett v. Blue Cross & Blue Shield of Ala., 890 F.2d 1137, 1140 (11th Cir.1989).
This court first examines whether the plan administrator's benefits-denial decision is “wrong.” Blankenship, 644 F.3d at 1355. Although Metropolitan Life based its preliminary denials on Wisconsin law, Moore argues—and the insurance company now...
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