United States District Court, Eastern District of Michigan, Southern Division
OPINION AND ORDER DENYING PLAINTIFF’S MOTION FOR JUDGMENT REVERSING THE ADMINISTRATOR’S DECISION (ECF NO. 13) AND GRANTING DEFENDANT’S MOTION TO UPHOLD THE ADMINISTRATIVE DECISION (ECF NO. 14)
LINDA V. PARKER, U.S. DISTRICT JUDGE.
This is an ERISA case. The parties filed dueling motions: Plaintiff Megan Schra (“Plaintiff”) filed a Motion for Judgment Reversing the Administrator’s Decision. (Pl.’s Mot., ECF No. 13 at Pg. ID 566.) Defendant Metropolitan Life Insurance Company (“Defendant”) filed a Motion to Uphold the Administrative Decision. (Def.’s Mot., ECF No. 14 at Pg. ID 575.) For reasons that follow, the Court DENIES Plaintiff’s motion and GRANTS Defendant’s motion.
Plaintiff applied for short term disability (“STD”) benefits under the STD plan with Defendant. (Pl.’s Mot., ECF No. 13 at Pg. ID 572.) Defendant notified Plaintiff on March 1, 2011, via letter, that Plaintiff was approved for STD benefits from February 14, 2011 – March 6, 2011. (AR 306.) On March 15, 2011, Defendant extended Plaintiff’s benefits through March 20, 2011. (AR 295.) Subsequently, Defendant notified Plaintiff, via letter, that it had extended Plaintiff’s STD benefits through April 17, 2011. (AR 277.) On April 29, 2011, Defendant notified Plaintiff that her claim for STD benefits had been withdrawn effective April 18, 2011, and that Plaintiff was entitled to appeal Defendant’s decision to withdraw her claim. (AR 244.) On May 31, 2011, Defendant notified Plaintiff that Defendant was in receipt of additional information Plaintiff had submitted in furtherance of her appeal of Defendant’s determination to terminate her claim for STD claim benefits. (AR 236.) On August 5, 2011, Defendant notified Plaintiff via letter that the determination to terminate Plaintiff’s claim for benefits beyond April 17, 2011 was upheld upon appeal review, that Plaintiff had exhausted her administrative remedies under the plan, and that no further appeals would be considered by Defendant. (AR 131.)
Subsequently, Plaintiff filed its Motion for Judgment Reversing the Administrator’s Decision, seeking “to recover long-term disability benefits pursuant to Section 502(a)(1)(B) of the Employee Retirement Income Security Act of 1974 (ERISA).” (Pl.’s Mot., ECF No. 13 at Pg. ID 568–69.) In her motion, Plaintiff asserts: (1) she was granted short-term disability benefits from February 14, 2011 – April 17, 2011; (2) Defendant informed her that if her disability were extended through May 16, 2011, it would automatically initiate long-term disability for her; (3) that her diagnoses did not change thereafter; and (4) that therefore, Defendant’s decision to deny LTD benefits was arbitrary and capricious. (Id. at Pg. ID 572–73.)
Thereafter, Defendant filed a Motion to Uphold the Administrative Decision. Defendant in its motion asserts that Plaintiff cannot maintain its claim for LTD benefits because Plaintiff never filed a claim for such benefits, and because Plaintiff failed to exhaust administrative remedies available had such claim for LTD benefits been denied. (Def.’s Mot., ECF No. 14 at Pg. ID 607.)
In response to Defendant’s motion, Plaintiff once again asserts that she was granted STD benefits from February 14, 2011 – April 17, 2011, that Defendant advised that if her disability were extended through May 16, 2011, it would automatically initiate long-term disability for her, and that to date her disability has not improved and she remains in the condition that was approved for STD benefits. (Pl.’s Resp. Br., ECF No. 15 at Pg. ID 726.)
Defendant, in its reply brief, asserts that it never made any determination regarding Plaintiff’s eligibility under the LTD plan. (Def.’s Reply Br., ECF No. 16 at Pg. ID 734.) Defendant concedes that it advised Plaintiff that if her disability extended beyond May 16, 2011, a claim for LTD benefits would be initiated on her behalf; however, Defendant asserts that it advised Plaintiff on August 5, 2011 that its determination that no STD benefits were payable beyond April 17, 2011 under the STD Plan was upheld. (Id. at Pg. ID 733–34.)
A motion hearing was held on November 5, 2014, at which Plaintiff informed the Court that she wanted to revise her request for benefits under ERISA. (Mot. Hr’g Tr. 5, Nov. 5, 2006.) Plaintiff requested that the Court allow her to amend the complaint to seek entitlement to STD benefits rather than LTD benefits under ERISA. (Hr’g Tr. 6.) Specifically, Plaintiff stated:
Your Honor, I would first like to address an issue concerning whether we should be even talking about long-term disability benefits. In this case, I only asked for long-term. So what I would like to do today, just to get the record clear, is let’s treat everything today as if I’m seeking short-term disability benefits because she did exhaust her administrative remedy and – and the arguments that [Defendant] would make would be the same today whether it was long – or short-term as to whether the denial of benefits was arbitrary and capricious…And I’m essentially, what I’m doing today is I’m making an oral Motion to Amend my complaint.
(Hr’g Tr. 5–6.) Defendant, in response to Plaintiff’s request, asserted that its STD plan is a payroll practice plan, not governed under ERISA, and thus the Court lacks subject matter jurisdiction over the matter, and that the Court should therefore deny Plaintiff’s request to amend his complaint. (Hr’g Tr. 12–13.) The Court requested that Defendant submit a post hearing brief by November 12, 2014, providing the Court with evidence supporting Defendant's assertion that the STD plan is a ...