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Metropolitan Life Insurance Co. didn’t abuse its discretion by denying $431,000 in life insurance benefits to the widower of a Southwest Airlines’ flight attendant ( Crawford v. Metro. Life Ins. Co. , 2017 BL 288634, N.D. Tex., No. 3:16-cv-02402, 8/17/17 ).
MetLife’s decision to deny the widower’s claim for benefits wasn’t arbitrary or capricious because the last valid beneficiary designation on file was for the decedent’s great-nephew, Judge Jane J. Boyle of the U.S. District Court for the Northern District of Texas held Aug. 17.
Boyle rejected the widower’s argument that his wife’s designation of her great-nephew was invalidated because of a change in the plan terms that took effect in 2013. Boyle agreed with MetLife’s interpretation that stating in the summary plan description that paper designation forms would no longer be accepted didn’t mean that previous paper forms were invalid.
The widower argued that MetLife failed to include a provision informing employees that designations made before 2013 would remain valid. If MetLife had included an additional sentence indicating that paper designations before 2013 would remain valid, any ambiguity would be resolved, he said.
Boyle’s decision is significant because it rejects the argument that plan administrators must include specific information in summary plan descriptions to avoid ambiguities. Boyle reasoned that if the widower’s logic was accepted, then any plaintiff could reject an administrator’s interpretation by arguing that the SPD is ambiguous because it lacks a sentence explaining the administrator’s exact interpretation.
Jessica S. Taylor and Kelly Durham & Pittard LLP represent the widower. Estes Okon Thorne & Carr PLLC represents MetLife.
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