Peters v. Reliance Standard Life Ins. Co.
Citation | 238 F.Supp.3d 905 |
Decision Date | 23 February 2017 |
Docket Number | CIVIL ACTION NO. 3:16–CV–60 |
Parties | Reginald PETERS, Plaintiff, v. RELIANCE STANDARD LIFE INSURANCE COMPANY, Defendant. |
Court | U.S. District Court — Southern District of Texas |
Michael Elton Pierce, Pierce Skrabanek Bruera, PLLC, Houston, TX, for Plaintiff.
Claire Winniford Parsons, Wilson Elser et al, Houston, TX, for Defendant.
Before the Court is Defendant Reliance Standard Life Insurance Company's Motion to Dismiss Pursuant to FED. R. CIV. P. 12(b)(6). Dkt. 8. This case stems from Reliance's decision to discontinue long-term disability payments to Peters. It did so after learning that Peters had entered a settlement agreement ("Agreement") with his employer. The Agreement allegedly released his employer and its insurers from liability. Peters claims that the Agreement did not release Reliance from its responsibility to continue paying disability benefits. For the reasons that follow, the Court GRANTS the motion to dismiss.
The undisputed facts, in the light most favorable to plaintiff as the non-moving party, are as follows. Reginald Peters ("Peters") was employed with Averitt Express, Inc. ("Averitt"). Peters obtained disability insurance with the defendant, Reliance Standard Life Insurance Company ("Reliance"), through his employment with Averitt. In 2011, Peters sustained injuries when he was struck by a tractor-trailer driven by another Averitt employee. Averitt was not a subscriber to the Texas Workers' Compensation System. Peters brought a suit in negligence against Averitt in the 152nd Judicial District Court of Harris County, Texas. Pursuant to this litigation, Peters and Averitt entered into the Agreement in which Peters received $2,500,000 in exchange for releasing Averitt from any future liability.
The following sections of the Confidential Settlement, Indemnity and Release Agreement are relevant to this case:
Reliance had paid Peters long-time disability benefits as required by the policy. However, Reliance ceased payments when it learned of the Agreement. When the payments stopped, Peters brought the instant suit against Reliance. Dkt. 1. According to Peters, Reliance's decision to cease paying long-term disability benefits: 1) was improper; 2) was improperly motivated by an attempt to avoid its obligations to pay benefits; and 3) interfered with his right to receive disability benefits. Id. The Complaint therefore asserted causes of action for: 1) denial of benefits; 2) breach of fiduciary duty; and 3) interference, seeking damages and injunctive relief. Id.
In its motion to dismiss, Reliance argues that Peters released it from any obligation to continue paying long-term disability benefits when he entered into the Agreement with Averitt. Dkt. 8. Its motion to dismiss points to language in the Agreement that 1) names Averitt's ‘insurers' as Releasees; and 2) discharges all Releasees from—inter alia —long-term disability or insurance claims. Id. Peters counters that Reliance was not a party to the Agreement, which did not specifically name Reliance as a Releasee—although it did expressly identify several other insurers of Averitt. Dkt. 9.
Through the Complaint, the motion to dismiss, and the parties' responsive pleadings and filings with the Court, Peters and Reliance disagree on many points of fact and law. However, two central issues have emerged: 1) the applicable law to apply and 2) whether, under the appropriate law, Peters released Reliance from its obligation to pay disability benefits.
The parties agree that the Court has federal question jurisdiction over this case pursuant to 28 U.S.C. § 1331 and—specifically—the Employee Retirement Income Security Act of 1974 ("ERISA"). See 29 U.S.C. § 1132(e)(1).
Pursuant to Rule 8 of the Federal Rules of Civil Procedure, a pleading must contain "a short and plain statement of the claim showing that the pleader is entitled to relief." Fed. R. Civ. P. 8(a)(2). A Rule 12(b)(6) motion tests the formal sufficiency of the pleadings and is "appropriate when a defendant attacks the complaint because it fails to state a legally cognizable claim." Ramming v. United States, 281 F.3d 158, 161 (5th Cir. 2001), cert. denied sub nom. Cloud v. United States, 536 U.S. 960, 122 S.Ct. 2665, 153 L.Ed.2d 839 (2002).
To defeat a motion to dismiss pursuant to Rule 12(b)(6), a plaintiff must plead "enough facts to state a claim to relief that is plausible on its face." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007). "A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal , 556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009) (citing Twombly, 550 U.S. at 556, 127 S.Ct. 1955 ). The court must accept the factual allegations of the complaint as true, view them in a light most favorable to the plaintiff, and draw all reasonable inferences in the plaintiff's favor. See Ramming , 281 F.3d at 161.
Rule 12(b)(6) motions to dismiss are "viewed with disfavor and [are] rarely granted." Arnett v. Aetna Life Ins. Co., No. CV H-15-2723, 2016 WL 6883203, at *2 (S.D. Tex. Apr. 14, 2016) (citing Turner v. Pleasant , 663 F.3d 770, 775 (5th Cir. 2011) ). A complaint need not address every potential affirmative defense to survive a motion to dismiss. Am. Surgical Assistants, Inc. v. Great W. Healthcare of Texas, Inc. , No. CIV.A.H-09-0646, 2010 WL 565283, at *2 (S.D. Tex. Feb. 17, 2010) (citing Hall v. Hodgkins, 305 Fed.Appx. 224, 228 n. 1 (5th Cir.2008) ). However, "[a]n exception to this rule may apply if the plaintiff has alleged facts plainly indicating that an affirmative defense does apply." Id. Further, "where facts alleged in Plaintiff's pleadings make clear that a claim is barred, dismissal under Rule 12(b) may be granted." In re Dynegy, Inc. Securities Litigation , 339 F.Supp.2d 804, 819 (S.D. Tex. 2004).
Congress enacted ERISA to regulate employee benefit plans. Aetna Health, Inc. v. Davila , 542 U.S. 200, 208, 124 S.Ct. 2488, 159 L.Ed.2d 312 (2004). Any plan that is "established or maintained by an employer...for the purpose of providing for its participants or their beneficiaries...benefits in the event of sickness, accident, disability, death, or unemployment" is governed by ERISA. See 29 U.S.C. § 1002(1). The parties agree that the instant claims are governed by ERISA. Though never expressly stated, the Court finds that the Complaint's three causes of action are made pursuant to the following ERISA provisions: 1) 29 U.S.C. § 1132(a)(1)(B) and (3) for denial of benefits; 2) 29 U.S.C. §§ 1104, 1109, and 1132(a)(2) for breach of fiduciary duties; and 3) 29 U.S.C. § 1140 for interference.
The parties further agree that federal common law controls.1 See Chaplin v. NationsCredit Corp. , 307 F.3d 368, 372 (5th Cir. 2002) (...
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...disability benefits arose out of the work-related injury that was settled in the Agreement. See Peters v. Reliance Standard Life Ins. Co., 238 F.Supp.3d 905, 912-13 (S.D. Tex. 2017) (release of long-term disability claim released along with underlying negligence claim). Accordingly, the Cou......